I mentioned the lack of precaution in a post at the time. Newton got the crap beaten out of him, including some headshots. I like Newton and would hate to see his career shortened like that. If the defenses know he’ll be kept on the field, they will take extra shots even if they face a penalty. He’s an essential player to his teams success.
If you lower your head and use the helmet as a ram into the head, it’s a deliberate head shot. Standing straight up and hitting heads? I just don’t know.