Crawn v. Campo

In Crawn v. Campo, 136 N.J. 494, 643 A.2d 600 (1994), the plaintiff, while playing catcher in a softball game with a no-sliding rule, was injured when defendant "approachedthe plate . . . lowered his body and barreled into plaintiff's left side." Plaintiff sued defendant for his personal injuries alleging that defendant was liable because his conduct had been either negligent, reckless or intentional. The principal issue before the New Jersey Supreme Court centered on the applicable standard of care: negligence or the heightened recklessness standard. Justice Handler, writing for a unanimous court, initially noted that physical contact was "an inherent or integral part of the game in many sports." Id. at 504, 643 A.2d 600. Relying upon case law throughout the country analyzing the standard of care applicable to contact sports such as football, hockey, basketball and softball, the court held that the heightened standard of recklessness or intentional conduct was applicable to sports. Id. at 497, 508, 643 A.2d 600.