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If a defender directs his action toward the head of an opponent you can call a personal foul. However if the opponent's actions cause his head to move into the location where the contact is initiated then you probably don't have anything. It is similar to when a defender may turn his back on a blocker at the last second. The blocker may have just committed a block in the back but the contact is not illegal as defender's actions caused the contact to occur that way. If the QB ducks his head at the last second then I don't have anything if what otherwise would be legal contact now happens against his head as opposed to his shoulders.
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