Hackbart v. Cincinnati Bengals, Inc., has drawn attention to the subject of violence in professional sports. However, the judicial system did not prove to be a successful avenue of redress for Hackbart, the injured professional football player. This Note discusses whether the court was correct in declining to declare "open season" on overzealous athletes who have injured an opponent, or whether it erected a precedential blockade for injured sports participants.

I. Introduction

II. The Facts

III. Historical Background

IV. The Hackbart Decision … A. Is There a Duty Owed? … B. The Defenses

V. Should the Courts Become Involved?