When people play sports, they sometimes get hurt. And Indiana law recognizes that when someone is hurt by another sports participant, there is generally no liability. That is also true if the participant that hurts another is a coach.C.G. was a freshman basketball player, and Hannah Amor was C.G.’s coach.
As the players practiced a layup drill, Coach Amor defended the goal and attempted to aggressively block or “swat” the player’s ball. As C.G. was running on the side of thebasketball court to receive a ball, Coach Amor blocked a layup by one of C.G.’s teammates. The ball hit C.G. and caused a concussion.
C.G. sued the school for her injuries, and the school moved for summary judgment. It argued that blocking a basketball shot is within the ordinary conduct expected in basketball, so the school was not liable. The trial court granted the motion, and C.G.appealed.
The central question on appeal was whether Coach Amor was a “sports participant” because a sports participant cannot be liable for conduct ordinary in the sport unless they injure someone intentionally or recklessly. C.G. argued that coaches cannot be sports participants under this rule, but the Court found the argument “unpersuasive.”
Coach Amor was not a promoter of a sporting event, and the exception noted in Pfenning does not apply here. Coach Amor also was not an “[e]vent organizer[ ], sponsor[ ], and the like” mentioned in Bowman. Rather, Coach Amor was acting as a defensive player and participating in drills during practice. The policy concerns cited by C.G. are inapplicable here. We conclude that Coach Amor was a sports participant, and the standard set forth in Megenity and Pfenning applies.
C.G. admitted that Coach Amor did not strike her intentionally, and made no argument that Coach Amor was reckless, so the trial court properly granted summary judgment to the school.
While the Court did not state its conclusion in these terms, it appears that the question of whether someone is a sports participant focuses on whether the person was engaged in the sporting activity in some tangible way. Coach Amor clearly met that test in this case, but there may be other cases in which the line more blurred.
Lesson: A coach who actively participates in practice as a player and, while engaged in conduct ordinary in the sport, causes injury to a student breaches no duty unless the injury was intentional or the conduct was reckless.