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Check that starts low, ends up in the neck

Correct Call: Cross check. 1 minute personal foul. This is one we have to be more consistent on. The check starts low but does end up in the neck. Per the rulebook, this should be a 1-3 minute non-releasable. How do we want to call this?
For this to not be a penalty: Keep the hands from sliding up into the neck.
Game Level:This could be called a more severe penalty on lower tiered games.
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