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While I agree in principle with what JRut says, I vaguely recall a college clarification or ruling coming directly from Art Heyland a few years ago when the swinging the elbows rule first came out indicating that a FF1/intentional foul should be called when the offensive player contacts the defensive player with the ball, above the defensive players shoulders, while excessively swinging their elbows, even though there was not contact with the offensive players arms. I can see how one can extrapolate that ruling to the situation described in the op, especially considering there is not anything written specifically about that type of play.
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