First, I think most defenders are more concerned about getting the receiver down on the ground and not getting burned to come up with something as devious as catching a receiver in mid-air and carrying them out of bounds. Second, this rule change was to remove the judgment call that a ref had to make as to whether he thought that a receiver would land in-bounds or not based on a defender knocking him out of bounds before he could get his feet down. There's no judgment call when a receiver catches a ball at the field numbers and is carried out of bounds - clearly the receiver would have landed in-bounds. See a situation like that and it will be called a catch.