That can happen for a couple fo reasons, BUT as far as I know, the most common way to cause this is to not have the top hat holder (whatever it's called I don't know, clutch or whatever) tightened completely, but left loose, just like the screws ont he cymabl stands - the looser they are, the more sway the cymbal can have. I also dare sya he has no tilt on the tilt adjuster either on the underside of the hat, if he has a tilt adjuster at all.
That's my bet how it's done
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