Shin

In Knight v. Jewett (1992) 3 Cal.4th 296 , 11 Cal.Rptr.2d 2 , 834 P.2d 696 (Knight) , we considered the duty of care that should govern the liability of sports participants. We recognized that careless conduct by coparticipants is an inherent risk in many sports, and that holding participants liable for resulting injuries would discourage vigorous competition. Accordingly, those involved in a sporting activity do not have a duty to reduce the risk of harm that is inherent in the sport itself. They do, however, have a duty not to increase that inherent risk. (See Avila v. Citrus Community College Dist. (2006) 38 Cal.4th 148 , 162 & 166, 41 Cal.Rptr.3d 299 , 131 P.3d 383 .) Thus, sports participants have a limited duty of care to their coparticipants, breached only if they intentionally injure them or "engage[] in conduct that is so reckless as to be totally outside the range of the ordinary activity involved in the sport." (Knight, at p. 320, 11 Cal.Rptr.2d 2 , 834 P.2d 696 , fn. omitted.) This application of the primary assumption of risk doctrine recognizes that by choosing to participate, individuals assume that level of risk inherent in the sport.

This case…