In Watson v. State of New York (52 NY2d 1022 [1981]) the plaintiff alleged that he was injured during a physical altercation with his teacher. The Court of Appeals ruled that, because the plaintiff had assaulted the teacher, he was barred from recovery by virtue of the doctrine of assumption of risk, since he, by assaulting his teacher, had assumed the risks of any injuries which may have foreseeably occurred (id. at 1022-1023).