California, United States of America
The following excerpt is from Ordway v. Superior Court, 198 Cal.App.3d 98, 243 Cal.Rptr. 536 (Cal. App. 1988):
6 Nabozny v. Barnhill (1975) 31 Ill.App.3d 212, 334 N.E.2d 258 exemplifies the confusion. A high school soccer goalie was injured when a rival player kicked him in the head as he held the ball within the 18-yard penalty area. He sued on a negligence theory, and the trial court directed a verdict for defendant.
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