I saw this in a varsity game this past weekend, and it has been bugging me. One team had a massive tight end (4 star prospect committed to a Big Ten school), who was being covered by players significantly smaller than him.
On one play with press coverage, he did a technique basically what I would say was similar to a swim move a defensive end might perform on an offensive lineman. As he was trying to pass his arm over the helmet of the player in coverage, he ended up swatting the defender pretty hard in the head. Whether or not it was intentional, the contact seemed to do enough to do the defender to allow the tight end to quickly get in to open space.
At the time, I had no flag. It certainly wasn't "violent" enough to justify a 9-4 personal foul
In hindsight, I think I could justify an illegal use of hands based on two violations of 2-3-3: swinging the forearm faster than the shoulder, and initiating contact above the head.
Thoughts?