In Goff v. Clarke, 302 A.D.2d 725 (3rd Dep't 2003) the Appellate Division determined that summary judgment was precluded by a factual issue as to whether a grapple between a high school athlete and his coach was on the one hand "jovial in nature," a playful contest engaged in with mutual consent which simply had unfortunate results, or on the other hand the result of the defendant's offensive and aggressive action.