When Are Athletes Liable for Injuries They Cause?

Plus a side note on Mormon church basketball.


In recent years, the Utah Supreme Court has produced many unusually interesting, thoughtful, and academic (in the best sense) opinions; here's another from last Thursday, Nixon v. Clay, written by Associate Chief Justice Thomas Lee:

At the outset of the oral argument in our court in this case, counsel for the appellee presented a quote from the late Senator John McCain. The quote alludes to the sport of mixed martial arts as a "dangerous and brutal exercise," while then warning of a "sport, more vicious and cold-blooded, that takes place in Mormon meetinghouses across this great nation of ours"—"LDS Church Basketball." This quote, sadly, appears to be a matter of internet apocrypha. We can find it attributed to a McCain floor speech on various pages of the world-wide web, but no such quote appears in the pages of the Congressional Record. Yet the apocryphal quote conveys an accepted view of "church ball" among many who have experienced this phenomenon—an athletic competition acclaimed on some local t-shirts as "the brawl that begins with prayer."

The court concluded that, as a matter of law, "participants in any sport are not liable for injuries caused by their conduct if their conduct was inherent in the sport":

Our cases have established a framework for the establishment of a duty of care in the law of torts. We have announced a "general rule" that "we all have a duty to exercise care when engaging in affirmative conduct that creates a risk of physical harm to others." And we have also explained that "[t]here are exceptions to the rule … in categories of cases implicating unique policy concerns that justify eliminating the duty of care for a class of defendants." In deciding whether to endorse an exception, we have looked to certain "'minus' factors" that may weigh against the imposition of a duty of care. Those factors include "the foreseeability or likelihood of injury," "public policy as to which party can best bear the loss occasioned by the injury," and "other general policy considerations." …

The Restatement (Second) of Torts states that a decision to "[t]ak[e] part in a game manifests a willingness to submit to such bodily contacts or restrictions of liberty as are permitted by its rules or usages." With this in mind, "[t]he majority of jurisdictions which have considered this issue have concluded that personal injury cases arising out of an athletic event must be predicated on reckless disregard of safety."

The majority rule establishes that a participant in a sport "breaches a legal duty of care to other participants—i.e., engages in conduct that properly may subject him or her to financial liability—only if the participant intentionally injures another player or engages in conduct that is so reckless as to be totally outside the range of the ordinary activity involved in the sport." The courts that endorse this rule have identified a series of policy rationales in support of this rule. We find these policy rationales quite persuasive.

Voluntary participants in sports "manifest[ ] a willingness to submit to … bodily contacts … permitted by its rules." They also submit to some bodily contact not permitted by the rules because "rule[ ] infractions and mishaps are virtually inevitable" in sports where bodily contact is inherent. Contact, both permitted by the rules and sometimes contrary to the rules, is a known and accepted risk of many sports. And "it is inapposite to the competitiveness of contact sports to impose a duty on participants to protect coparticipants from … known and accepted risks."

If participants faced liability every time contact with another player resulted in an injury, a "flood of litigation" would ensue. "[V]igorous participation in athletic activities" would be deterred. Athletic competition "as we know it would not be played." And our society would be worse off as a result….

For these reasons we think it appropriate to establish an exception to tort liability for certain injuries arising out of voluntary participation in sports. But we do not deem it appropriate to require proof that a defendant's conduct was reckless or intentional. Nor do we think it is necessary to limit the exception to an arbitrary subcategory of "contact" sports. Instead we hold that voluntary participants in a sport cannot be held liable for injuries arising out of any contact that is "inherent" in the sport. Under our rule, participants in voluntary sports activities retain "a duty to use due care not to increase the risks to a participant over and above those inherent in the sport." But there is no duty to lower or eliminate risks that are inherent in an activity.

We depart from the majority rule in part because we find the "intentional or reckless" conduct standard unnecessary and potentially problematic as applied to some sports. Under the majority rule, sport "participant[s] [are] liable for injuries … if the participant's conduct was 'either deliberate, willful or with a reckless disregard for safety of the other player.'" In applying this standard most jurisdictions endorse the Restatement definition of recklessness:

"[An] actor's conduct is in reckless disregard of the safety of another if he does an act … knowing or having reason to know of facts which would lead a reasonable man to realize, not only that his conduct creates an unreasonable risk of physical harm to another, but also that such risk is substantially greater than that which is necessary to make his conduct negligent."

This standard seems problematic in at least some sports. In sports like football, rugby, ice hockey, and other high-contact sports, contact between players is often simultaneously intentional or reckless and inherent in the game. Even contact technically prohibited by the rules, like a personal foul in the game of basketball, is rather routinely initiated intentionally as an element of game strategy…. And some conduct in high-contact sports will at least sometimes be the kind of conduct that is in "reckless disregard of the safety of another"—at least in the sense that there is a known, high risk of physical harm to another player.

In high-contact sports—where intentional conduct is expected and even encouraged—the majority rule could impose liability on players for simply playing the game as it is designed and expected to be played. Injuries arising out of such contact are of course unfortunate. But they do not warrant tort liability….

If a defendant's actions are inherent in a sport, the defendant should not face liability. And if the defendant causes injury through conduct not inherent in the sport, he or she should face liability under ordinary tort principles. A participant's state of mind may be relevant to the inherency inquiry; but a showing of intentional or reckless conduct is not necessary. If a participant in a sport initiated contact for the sole purpose of injuring a co-participant, for example, and not for a purpose that is strategic to or inherent in the game, that may suggest that the contact was not inherent. And merely negligent acts, on the other hand, may more often be seen as inherent. But again the key question is whether any given contact is inherent in the sport. The defendant's state of mind is at most a factor of circumstantial relevance….

The inherency inquiry will depend on the facts of a particular case and the characteristics of a particular sport. We adopt no uniform standard that will easily resolve all cases. But we outline below a few guiding principles to aid in the application of this exception.

Contact that is permitted and anticipated by the rules of a sport is clearly inherent. But inherency should not be based solely on what is permitted or prohibited by the rules of the game. "[Many sports] permit some bodily contact and, in actual practice, more contact is permitted than a reading of the rules would indicate. … [P]layers regularly commit contact beyond that which is permitted by the rules even as applied. In basketball, such an illegal contact is described as a foul for which a sanction is imposed. Sometimes the player fouled is injured. This is to be expected."

When determining whether contact, prohibited or not by the rules, is an inherent risk of the sport, courts should consider factors like the frequency at which this type of contact occurs, the circumstances in which it occurred, whether the contact is an aspect of the regular strategy of the game, and the severity of the sanction imposed by game officials…. { This inquiry may leave some difficult cases at the margins. But there will also be easy cases at opposite ends of the spectrum. A common personal foul involving a routine basketball move (like an attempt at the ball that results in a hack across the arm), for example, is easily classified as inherent in the game of basketball, as it is frequent, results only in a minor sanction, and is obviously strategic. An example of non-inherent contact in basketball, by contrast, might involve a bench-clearing brawl in which punches are thrown at an opponent. This is unfortunately not unheard of. But it is infrequent, not a matter of the regular strategy of basketball, and results in severe sanctions (ejection and even suspension and fines).

This latter example also highlights the danger in attributing too much significance to the "strategic" nature of an act. A player could conceivably find some strategic value in throwing a punch at a star player from the other team—in an attempt to prompt a fight or otherwise take him out of the game. But that sort of move is not part of the regular strategy of basketball. And it would not be inherent in basketball because it is (thankfully) sufficiently infrequent that no reasonable basketball player would be seen as impliedly consenting to this kind of contact.} …

We depart from the majority rule in one additional way. The exception we create is not a "contact sports exception" with application only to those sports that courts deem "contact sports." The "contact sport" inquiry has led to some rather arbitrary line-drawing, typically hinging on how much contact is anticipated by the sport as a whole. Such line-drawing seems unnecessary. Even "non-contact sports"—sports that anticipate only incidental or infrequent contact between co-participants—should be subject to the protections of the exception outlined above.

An example may be helpful. The game of tennis does not involve frequent bodily contact among participants in the sport. For that reason this sport conceivably might not qualify as a "contact sport." But there are obvious risks of injurious contact in tennis. Players may anticipate getting hit with a tennis ball or colliding with a teammate during a doubles match. And tennis players in these situations should be exposed to no more liability for injuries caused by their contact than a basketball player who collided with another player during a game. The amount and degree of contact inherent in a sport is not the key inquiry; the key question is whether the contact that did occur is inherent in the sport….

And the court concluded that, on these facts, the defendant wasn't liable:

Judd Nixon and Edward Clay were playing on opposite teams in a church-sponsored recreational basketball game. Nixon dribbled the ball down the court to take a shot. Clay pursued Nixon to try to contest the shot. As Clay approached Nixon's right side he extended his right arm over Nixon's shoulder to reach for the ball. Nixon came to a "jump stop" at the foul line and began his shooting motion. When Nixon came to this sudden stop, Clay's arm made contact with Nixon's right shoulder. Nixon then felt his left knee pop. Both men fell to the ground. The referee determined that the contact was not intentional and warranted only a common foul. Nixon unfortunately sustained a serious knee injury in the collision….

The undisputed facts demonstrate that Nixon's injury was caused by contact inherent in the game of basketball. And the sport exception that we establish forecloses the imposition of liability when an alleged tortfeasor's conduct is inherent in the sport.

Nixon concedes that he was injured when Clay initially made contact with his right shoulder. The testimony and photographs presented on appeal indicate that this initial contact occurred when Clay attempted to "reach in" and "swipe at the basketball" to prevent Nixon from making a shot. And it is undisputed that reaching in for the ball and swiping at the ball are common basketball moves. It is likewise undisputed that fouls, both accidental and intentional, are a part of the game of basketball—so much so that each player is permitted five fouls per game. In this case, spectators at the game and the referee testified that Clay's contact was properly classified as a common foul.

Nixon … asserts that Clay did more than just reach in and swipe at the ball. He alleges that Clay "tackled" him. And "tackling," Nixon argues, is not inherent in the game of basketball. This is insufficient, however, because Nixon's allegation of tackling is immaterial. Nixon concedes, after all, that his injury happened during Clay's swipe and not as a result of the alleged "tackle." And because the parties agree that the injury did not occur during the "tackle," we need not decide whether some form of "tackling" is inherent in the game of basketball….

Clay did not owe Nixon a duty to avoid "reaching in" and "swiping at the ball" because such conduct is inherent in the game of basketball. And absent such a duty, there can be no liability….


NEXT: Justice John Paul Stevens, RIP

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  1. In the early days of MMA, when the rules were very minimal (I think there was no biting, etc. but that’s about it) and they didn’t wear gloves, John McCain did call it human cockfighting. It really was a fun time, in that every martial art had this idea that they had better techniques, so it was a karate practitioner vs a judo player or a kung fu guy. Once we worked out that it was kickboxing with a mix of grappling skills either from wrestling/judo/Jujutsu that worked the best in all circumstances, they could implement safety rules and get sanctioned.

    1. But that was as much as a deliberate marketing strategy — “There are no rules!” — than because it was unsettled what techniques were effective. It’s not like matching the bans on biting and eye-gouging with a ban on, say, blows to the groin and fish-hooking would have unfairly disadvantaged any of the rival schools of martial arts. Rather, allowing things that would have been fouls in any other competition was deliberate marketing as “extreme”, and things like McCain calling it “human cockfighting” helped draw adolescent male audiences.

      Then, after audiences had built up, it converted itself from a spectacle into a respectable sport.

      1. I think you’re reversing causality. The “there are no rules” was part of the marketing because the purpose behind the whole endeavour was not to create artificial rules that benefited one martial art over another. By comparison, if two people want to have a race to see who wins, they are having the race to see who wins. That they go fast is implicit in deciding to race. That people watch a race because people go fast is merely the draw, but in the end the reason to have the race is to decide who wins.

        So once the new style emerged, it didn’t matter that limited safety rules, such as light gloves to protect hands, and blows to the top of the head, and knee strikes from the ground, disadvantaged everyone, because it did so to the people practicing the new style equally, and not any one traditional style over another.

        Anyway, what the ended up doing was recreating what the ancient Greeks already knew, in Pankration.

  2. Flashback to 2005, where Loser Pays went nowhere in Utah.

  3. Filed complaint three years after the injury. Arising from an injury from church. I searched the decision PDF for “insurance”, with no results, buuuuttttt…I wonder of this was one of those cases brought because the injured’s health insurance wouldn’t pay claims from the injury, but would if the courts didn’t find the injurer at fault (especially if they thought the other side had deep pockets). [insert thinking face emoji]

    1. in every common situation I’m familiar with, health insurance doesn’t care about fault when deciding whether to pay, and fault would only come in if the health insurance were looking for subrogation from another insurer (in which case the named parties would probably be insurance companies, or at least they would feature prominently).

  4. “The court concluded that, as a matter of law, “participants in any sport are not liable for injuries caused by their conduct if their conduct was inherent in the sport””

    But what is inherent in the sport? Each sport has forbidden actions that are better defined than most laws, and for which there is a prescribed penalty, which might be as minimal as to disadvantage the participant (loss of yards, loss of point, etc.) financial penalty, expulsion from the game or even the sport entirely. Might depend on whether the aim of the penalty is to eliminate the infraction, or merely make the decision for infraction interesting.

    So is fouling in basketball an inherent part of the game, though forbidden and penalized by rule? Likely part of the game, since the penalty is less than the perceived benefit; the sport had deemed that fouling should continue (and draw out the last 30 seconds of the game interminably)

    Targeted hits in college football? likely not inherent to the prescribed play, as the sport has set a penalty steep enough that such hits are not strategically valuable. Targeted hits are prohibited because they are inherently dangerous and are not part of the game any longer.

    1. Fouling [called or not] occurs dozens [hundreds?] of times each basketball game.

      Holding or other illegal blocks in football probably occur every play.

      These actions are just as inherent as dribbling or passing.

    2. I agree, the inherent standard is unworkable e.g., what about hockey fights? what about errant golf shots? I’d have gone more along the lines of “outrageous given the norms and customs of the sport,” then threw it to expert testimony and juries.

      That said, I wouldn’t be stunned if most of these were friendly lawsuits e.g., a substitute for insurance coverage.

      1. “what about hockey fights?”

        What about them? According to the opinion, “courts should consider factors like the frequency at which this type of contact occurs, the circumstances in which it occurred, whether the contact is an aspect of the regular strategy of the game, and the severity of the sanction imposed by game officials.” It’s likely those answers may be different for different levels and even types of fights. If it’s the NHL and you square up before fighting, I bet there’s no liability under this standard. If it’s your local rec league, and you sucker punch a guy, I bet there is.

        “what about errant golf shots?”

        How is there any question that errant golf shots are an inherent part of the game?

        1. I think hockey fights are more in line with existing law for mutual combat, which generally allows lawsuits for assault and battery. But this may be one case where resort to foreign judicial proceedings would be justified since Canadian Hockey law seems particularly well developed:

          The seminal case on battery and assault in sports is Agar v Canning.10 This case involved an on-ice fight that rendered the plaintiff unconscious. In finding the defendant liable for battery, the court noted that injuries inflicted with a “definite resolve” to cause serious harm “should not fall within the scope of implied consent”. Implied consent can thus be defined by distinguishing the ordinary blows and collisions incidental to play from deliberate and unnecessarily harmful acts.12Overall, the decision affirms that an intentional blow or collision will not, on its own, attract liability. A defendant will only be found liable if his or her intentional act is coupled with an intention to injure another player.

        2. Fights in basketball or baseball (much less hockey) are fairly common, yet specifically called out as inherent. Hitting someone with a golf shot is pretty rare, yet I’d tend to say it’s part of the assumption of the risk when I step onto a course.

      2. If you hit me with a honestly struck golf shot (meaning you meant for it to go toward the hole, not toward me), that’s just a risk you took stepping on a golf course. And hey, hopefully you yelled “Fore!”.

        If I beat you with a golf club because you hit me with your errant shot and failed to yell “Fore!”, you probably have a case for assault&battery.

        1. Yeah, but it would make golf a lot more interesting.

    3. But what is inherent in the sport?

      That could still be litigated. And even above, the Justice states that tackling is likely not inherent. But since the “tackle” wasn’t the cause of the injury, there was no reason to judge if it was inherent to the risk of basketball.

      Any extreme foul is likely possible to litigate.

    4. Sure, it has grey areas, but so does every law, especially common law torts. This seems much better than “intentional or reckless” to me. When you’re boxing, punching a guy in the face is pretty intentional. But it’s inherent in the sport, no liability. And I agree that the severity of the in-game penalty is going to be a factor; in fact, such a strong factor it will often be determinative, I predict. If something could get you ejected, suspended, etc., that’s strong indication that the rules are actually trying to stop that behavior as much as possible (usually because of its danger) rather than just be something designed as a consequence or tradeoff (intentional fouls in basketball are a great example of this).

  5. I co-wrote a law review article ,(“Abusing Duty”), mostly critical, about this sort of analysis after the California Supreme Court went down this road in Knight v. Jewett. But the California Court at least recognized a recklessness exception. This is worse.

    1. I think the got it exactly right, it seems like they have more than a passing familiarity to church basketball.

  6. Ohio has the same basic rule.

  7. “[P]articipants in any sport are not liable for injuries caused by their conduct if their conduct was inherent in the sport” Well said.

    Sixty, or so, years ago saw a teammate kicked a downed opponent in the face (open in those days) while wearing football cleats. No penalty was called, but knowing the guy and seeing the kicking . . . it was deliberate, i.e., not “inherent in the sport.”

    1. kick not “kicked”

  8. I’m not sure a world in which sports teams (even church ones) had insurance to cover sports injuries that are “inherent to the sport” would be such a terrible world.

    1. How about just relying on everyone’s own personal insurance and tolerance for risk? Why create the bureaucracy necessary that every church softball team or community bowling league, had to have insurance for its players. It would be a real disincentive. This case is clearly out on the margins.

      1. Only in the sense that it’s a case at all. I’ve played basketball with Mormons (in their churches) and they’re as brutal as playing with Marines, if not so fast given the physical abilities of the players.

        Injuries like this appear to be are well within the norm, even if rare. And while I’ve seen marines carry their injured off the court, I’ve never seen them all pray for him while doing so.

        Maybe this guy’s upset that he didn’t get the normal Mormon healing prayers? Assuming he is a Mormon still, they’ll probably pay his bills – it’s one of their religious obligations.

      2. How about just relying on everyone’s own personal insurance and tolerance for risk?

        Works well enough, but as a rule-of-thumb I’m in favor of baking-in all the expected costs into the price-of-admission. Paying only for the entrance, and putting off paying for the clean-up often means that the clean-up doesn’t get paid for, no?

        That said…

        It would be a real disincentive.

        Only for sports that expect to have costly injuries. And if your sport can expect to have costly injuries, then requiring a person be prepared for that prior to entrance isn’t unreasonable.

    2. Most (maybe all) injuries are covered by many individual medical and / or liability policies now.

    3. I don’t think it would be a terrible world, but I do think it would be a worse world with fewer leagues and fewer people playing because of the additional costs. Of course, you still would need decisions like these because people can get hurt just as easily in pickup games.

  9. “…If a participant in a sport initiated contact for the sole purpose of injuring a co-participant, for example, and not for a purpose that is strategic to or inherent in the game, that may suggest that the contact was not inherent…”

    This immediately made me think of baseball, and the intentional beanball. (Obviously, the accidental beanball falls outside this, even though accidental injuries and even death have occurred…errant pitches are obviously an inherent risk in the sport of baseball.)

    But what about the intentional beanings? The pitcher is absolutely trying to intentionally injure the batter. Does it matter that the intended injury is supposed to be exceedingly minor? (e.g., a small black-and-blue mark for a few days, where the ball was aimed at the batter’s butt or upper thigh or lower back) I guess that the question of injuring being the sole purpose gets sorta meta. ‘Yes, I hit him with the pitch to send a message. Stop beaning our own players. Stop crowding the plate. etc etc.’

    But it’s hard for me to see just about any situations where there is no strategic benefit to injuring another player…getting her or him out of the game is, of course, usually determinative in the case of any elite athlete . . . get Clayton Kershaw or Michael Jordan out of the game at the very beginning and your chances of winning go up enormously. I do not see how this ‘exception’ does not swallow the rule . . . how could anything be liable when there is such a huge strategic advantage to injuring a player on the other team?

    1. “This latter example also highlights the danger in attributing too much significance to the “strategic” nature of an act. A player could conceivably find some strategic value in throwing a punch at a star player from the other team—in an attempt to prompt a fight or otherwise take him out of the game. But that sort of move is not part of the regular strategy of basketball. And it would not be inherent in basketball because it is (thankfully) sufficiently infrequent that no reasonable basketball player would be seen as impliedly consenting to this kind of contact.}”

    2. Because batters get hit regularly accidentally, it would be hard to prove actual intent. Even if every “knew” it was intentional, a pitcher can still say “I was just trying to throw a high fastball over the inside corner, and it got away from me.”

  10. The pitcher is absolutely trying to intentionally injure the batter.

    There’s a difference between intentional pain and intentional injury. They most certainly aren’t trying to disable someone so that they won’t be able to play.

    And if you intentionally throw at someone’s head, one could easily argue that the pitcher should be liable. The hard part is proving that.

    1. MP,
      Your distinction is true IF the standard is “bad injury.” But if the standard is just any injury, then my point stands. In torts, we all learned the first week or two about the eggshell plaintiff. If I try to hurt you a tiny tiny bit, but a huge and unexpected injury results, I am liable…even though a reasonable person would not have anticipated that you happened to be the one person out of a million with an eggshell skull. By that logic, if I try to injure you a tiny bit (hitting you in the rear end with a pitch), I should be liable if something far worse results. You say that (in normal cases) beanball caused a pain but not an injury. I don’t think is, legally, correct…even small injuries are seen as, well, injuries.

      1. The eggshell plaintiff should not have chosen to play that sport.

        Sports become impossible if one must assume that the other players may be unusually susceptible to the usual hazards of the sport. For baseball, that includes being hit by a thrown or batted ball, as well as collisions between a baseman and a base runner – these things happen unintentionally all the time, and outfielders will actually run _towards_ a batted ball that is faster than the fastest pitch. For football, hockey, soccer, and basketball, that includes players careening into each other at high speed – sometimes these collisions were intentional and within the rules of the game, sometimes they are accidents because one player can’t predict (and may not even be able to see) the other. At least in hockey and basketball, sometimes high-speed collisions are intentional fouls, perhaps to warn the other side not to press so hard – and at professional levels, this happens often enough that I would have to consider such fouls part of the game play.

  11. “Come and see the violence inherent in the system!”

    Sorry, couldn’t help myself. 🙂

    1. There is never a bad time for a Monty Python reference!

  12. If you are going to reach for a coward’s distraction to avoid commenting on the important events of the day, I suppose burning issues in Utah scholastic sports would be as good a reach as any.

    1. Come on. This is a legal blog, and it seems petty to complain about a conspirator posting about an interesting case.
      So we have a racist president. We knew that before this past weekend. So we have an attorney general who will whore his integrity to protect said president. There are lots and lots of political websites that post political stories more regularly. Let’s enjoy this website for what it is, rather than lament what it is not (and was never intended to be).

      I tend to enjoy many of your posts. But this particular one seems particularly off-base. IMO only, of course. 🙂

      1. I almost alway enjoy RALK’s posts too. Cut him a bit of slack, please. He’s normally so pilloried for his observations and comments that you’d think he was the devil incarnate.

      2. This is an intensely political and partisan website, at least as much political and partisan as it is legal. With respect to Pres. Trump and what has become of the Republican Party and movement conservatism for which the Conspiracy is a polemical advocate, it has become cowardly and a hypocritical censor.

        I believe my shots aim no lower than those the Conspiracy directs toward liberal-libertarian institutions.

        May the better ideas win.

    2. Why can’t the VC attract a better caliber of trolls than Kirkland?

      1. It does. Read just a few posts. You’ll see them. (Hint: If a post uses the term “butt-sex” to try and make readers squeamish about male homosexuality; it’s probably a troll. If a post has to spell it Klinton–or even better, KKKlinton–it’s probably a troll. Same with Obongo vs Obama.)

        For some subjects, the number of trolls is larger than the number of normal good-faith posters. Alas. It’s my view that things have become much worse with the move to the Reason site. But I also felt that things got much worse when Eugene moved from his own site to WaPo. The downside of exposure to a wider audience . . . VC was a very different animal back when a large portion of its audience was lawyers and law students.

  13. Sounds like a straightforward application of implied waiver. The fact that some states flatly disallow implied waiver for coming to the risk is the only complicating factor.

  14. […] Are Athletes Liable for Injuries They Cause?” [Eugene Volokh on Nixon v. Clay, Utah Supreme […]

  15. “It is likewise undisputed that fouls, both accidental and intentional, are a part of the game of basketball—so much so that each player is permitted five fouls per game.”

    I agree with that statement. Purely, accidental and intentional, it may be risky for everyone in the accident.

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