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I can't tell from this angle what he actually hit with. He turned in a way that made it look like he wanted to use his shoulder. However, that also put the crown of his own helmet in the line of fire. It might also be considered that he targeted the opponent's head with his shoulder, although it's not clear he made contact that way either.
You might try to make a case for a more general provision of unnecessary roughness being applicable here, but that's not a given either. There was someone attempting a tackle but failing to stop the runner's progress, and who's to say a high, fast hit wasn't necessary to kill his momentum?
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