For many years, the doctrine of assumption of risk was broadly applied to participation in sport and recreation activities with the result that few, if any, courts imposed liability on aparticipant for injuries inflicted upon another. Courts did not want to “chill the vigor of athletic competition” and found it difficult to determine whether injuries were intentional. However, recent trends showing increased skill and strength of participants and increased violence in sports participation have resulted in the courts extending “some of the restraints of civilization” to athletic and recreational participation. Today the majority view is that participants in an athletic event owe a duty to other participants to refrain from reckless misconduct and liability may result from injuries caused a player by reason of the breach of that duty.>
