According to record wise that is correct, but the public perception is no. Not trying to ignorant...
Indy, as long as Manning is there they are a perennial threat every year to win the SB. No questions here.
Tennessee, extremely well coached team with maybe the best player in the NFL, consistent performer that also plays physical D.
Houston, some talent, but look until they make the playoffs nothing to really to talk of. Young team, can't really stop the pass. Has the ability to win and lose to anybody. Future is bright.
Jax, is awful despite their record.
AFC East has to be in the discussion if not the favorite or toughest division, even Buffalo despite their 0-7 record is in every game. Miami wins all their games on the road. NE-NYJ are what they are.
AFC North, Pitt and Balt fairly consistent, lean towards Balt being better with more options on offense and defenses are close. Cincy is a disappointment, and Cleveland isnt that bad. I would take both of them over Jax.
Now who would you take....
NE vs Indy, flip a coin
NJY vs Tenn, NYJ
Miami vs Houston, flip a coin
Jax vs Buffalo, Jax already beat them
Baltimore vs Indy, IMO I would take Baltimore
Pitt vs Tenn, Pitt already beat them
Cincy vs Houston, probaly lean Houston
Cleveland vs Jax, flip a coin
NE vs Baltimore, NE already beat them
NYJ vs Pitt, Pitt Sanchez will shit himself
Miami vs Cincy, Miami already beat them
Buffalo vs Cleveland, flip coin
By looking at that model above, I would lean towards the AFC East being the toughest division based off of NE, NYJ, and Miami. I will go back to sleep now....