This probably couldn't have been easier for Brendan Shanahan and his staff. Winchester's elbow has so much wrong with it. From leaving his feet to sticking out his elbow and making contact with Kelly's head, a hit like that should never happen.
Since Winchester has never been suspended or fined in his career and Kelly didn't suffer any injury, three games is a pretty fair suspension, if even a little light.
There's no place for hits like that in the game.