Does the Duty to Refrain from 'Willful and Wanton Conduct' Also Apply to Full-Contact Sports ?

In Karas v. Strevell, 227 Ill. 2d 440, 884 N.E.2d 122, 318 Ill. Dec. 567 (2008), the plaintiff was an ice-hockey player who allegedly sustained injuries when he was body checked from behind by two opposing players, and he alleged that this sort of bodily contact, or the toleration of it by officials, amounted to negligence and willful and wanton misconduct. All the ice-hockey players understood, however, that violent, stunning, bruising collisions were the way the game was played. Karas, 227 Ill. 2d at 456, 884 N.E.2d at 132-33. For that reason, in Karas, 227 Ill. 2d at 457, 884 N.E.2d at 133, the supreme court decided that the duty it had formulated in Pfister--the duty of a participant in contact sports to refrain from intentionally or willfully and wantonly injuring a coparticipant (Pfister, 167 Ill. 2d at 427, 657 N.E.2d at 1018)--would be unfair to participants in full-contact sports, such as ice hockey and tackle football. The duty would be unfair because "willful and wanton conduct" is, by definition, "'a course of action which shows actual or deliberate intent to harm or which, if the course of action is not intentional, shows an utter indifference to or conscious disregard for a person's own safety or the safety or property of others'" (Karas, 227 Ill. 2d at 455, 884 N.E.2d at 132, quoting Pfister, 167 Ill. 2d at 421, 657 N.E.2d at 1016), and in full-contact sports, a conscious disregard for the safety of the opposing player is inherent in the game, as all the participants fully understand before they skate into the rink or set foot on the field. Karas, 227 Ill. 2d at 456, 884 N.E.2d at 132. You cannot knock someone off his feet, or bounce him off a wall, while having a regard for his safety.