Koffman v. Garnett
Supreme Court of Virginia
574 S.E.2d 258 (2003)
Thirteen-year-old Andrew Koffman had never played football before joining his middle-school team. After criticizing the team's tackling, assistant coach James Garnett (defendant) ordered Andrew to hold a football and stand upright and motionless, then lifted him at least two feet off the ground and slammed him down; Andrew weighed about 144 pounds to Garnett's 260, and the throw broke Andrew's arm. No coach had ever used physical force to instruct players before. Andrew's parents (plaintiffs) sued Garnett for gross negligence, assault, and battery; the trial court dismissed the complaint, and the Koffmans appealed.
Whether a plaintiff may sue for battery upon being injured while playing an organized sport if he did not expressly or implicitly consent to the harmful contact.