Hackbart v. Cincinnati Bengals & Charles Clark
United States District Court for the District of Colorado
435 F.Supp. 352 (1977)
During an exhibition game, Denver Broncos player Dale Hackbart (plaintiff) tried to block Cincinnati Bengals running back Charles Clark (defendant). Out of anger, though without a specific intent to injure, Clark struck Hackbart on the back of the head with his forearm. No penalty was called, and Hackbart played through the rest of that game and two more before seeking medical care, ultimately being diagnosed with a neck injury. Hackbart's team paid his full salary for the season under his contract. Hackbart then sued Clark and the Bengals in tort.
Whether an NFL player assumes the risk of injury by choosing to play a known, violent sport, barring recovery in tort for an in-game injury.