Philadelphia Flyers forward Chris VandeVelde caught Chicago Blackhawks captain Jonathan Toews with a headshot Wednesday night.
VandeVelde received a two-minute minor for elbowing with 30 seconds left in the first period, and the league reportedly wasted little time looking into it.
Toews gave the Blackhawks a 2-1 lead less than five minutes into the second, scoring his 25th goal of the season.
VandeVelde was suspended three games by the AHL for a hit to the head in 2012.