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One would presumably think that bowling is one of the safest sports around, there being no physical contact, and the bowler handling the equipment. But injuries do occur in bowling, and sometimes completely unusual and certainly uncontemplated ones at that.

The rule in Missouri is that “when athletes are engaged in an athletic competition; all teams involved are trained and coached by knowledgeable personnel; a recognized set of rules governs the conduct of the competition; and a safety rule is contained therein which is primarily designed to protect players from serious injury, a player is then charged with a legal duty to every other player on the field to refrain from conduct proscribed by a safety rule. A reckless disregard for the safety of other players cannot be excused.”

In a recent decision, the Missouri Court of Appeals held that, because of the absence of physical contact, the “foreseeable risks in bowling differ in kind and degree from those traditionally associated with contact sports,” and thus approved a case tried on a negligence theory rather than the usual (in a sports injury case) recklessness standard.

Thus the Court allowed an award of damages to stand where a bowler was injured by, (and to borrow from noted syndicated columnist Dave Berry) “I am not making this up,” a bouncing bowling ball that (“I am still not making this up”), hit the injured bowler in the head. Even more amazing is that an eleven year old child’s failure to maintain a grip on the bowling ball resulted in the ball becoming airborne, hitting a step and bouncing into the head of the injured bowler.