what isn't shown clearly on those replays is that the ball was being bobbled and Battle went in to get it. Shoulder hit the head as the receiver was going down. Letter of the law it's a penalty, but as noted, not why the rule was installed.
And God forbid if they go to level's of targeting now, like Flagrant 1 or 2. While it might clear things up, would lead to way longer and more replays