Elbow contact above the shoulders.

[OKREF]

Originally Posted by jeremy341a

I agree to this and I am also fine with it being interperted as stationary. However if the pivioting elbow is indeed to be ruled as stationary then we do not need 3 levels in the POE: stationary, moving, and excessive. We only need two levels of stationary and excessive.

Not true.
Contact with a stationary elbow( elbow moving at the same speed as torso) may be a common foul or nothing.

If the elbow is moving faster than the torso, but not excessive, that would be intentional.

If it is excessive, it can be intentional or flagrant personal foul.