Thomas v. United States Soccer Federation
Supreme Court of New York, Appellate Division
653 N.Y.S.2d 958 (1997)
Octavio Thomas (plaintiff), playing in a game sponsored by the Cosmopolitan Soccer League and the United States Soccer Federation, Inc. (defendants), was suddenly attacked by an opposing player and fans who ran onto the field, with no prior history of animosity between the teams. Thomas sued, alleging the defendants negligently failed to provide adequate security and a well-trained referee; the trial court denied the defendants' summary judgment motion, and they appealed.
Whether, where a third party's intentional or criminal act intervenes between the defendant's conduct and the plaintiff's injury, the defendant can be held liable if the intervening act is a normal or foreseeable consequence of the situation created by the defendant's conduct.