The hooker picked up Daly and dumped him on his back in the second minute at Twickenham, receiving a yellow card – seen as lenient by some – from referee Mathieu Raynal.
Daly attempted a return to the action following a Head Injury Assessment before being permanently replaced soon after.
Scotland went on to lose 61-21 as England retained their Six Nations crown, but Brown has subsequently been cited and, if the disciplinary committee upgrades his transgression to a red-card offence, he will face a suspension.
Brown’s hearing is to be held in London on Tuesday, with Scotland hosting rock-bottom Italy at Murrayfield on Saturday in Vern Cotter’s final match in charge.
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