I think Clowney's defense says it all. "I wasn't trying to hurt him." Thing is that "trying to hurt him" is not, and never has been, the standard. He piled on a guy who was already down, helmet first. That gets flagged all the time, and nobody claims that all those penalties are based on "you tried to hurt him." I think in most cases that would draw a flag, but it really doesn't matter what would happen 'in most cases' because in some it wouldn't and in this one it didn't and that's how it goes.