The United States Court of Appeals for the Tenth Circuit has allowed a professional athlete to recover for an injury caused during a game by the reckless misconduct of an opponent in violation of game rules and customs.
Hackbart v. Cincinnati Bengals, Inc., 601 F.2d 516 (10th Cir.), cert. denied, 444 U.S. 931 (1979).
David S. Horvitz,
Tort Law - Reckless Misconduct in Sports,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol19/iss1/11