To those unfamiliar with the customs of professional hockey, observing a referee stand by while players drop their gloves and duke it out can be a disconcerting experience. Even more disconcerting is watching last week's highlights illustrate in slow-motion detail the bone-crushing force with which one player slams another into the boards. The professional hockey fan, however, knows that acts like these are the byproducts of a fast and furious game that recognizes physical intimidation as a legitimate strategy.2 In McKichan v. St. Louis Hockey Club,3 the Missouri Court of Appeals for the Eastern District of Missouri ruled that severe body checks administered moments after a play are "part of the game of professional hockey,"4 and therefore are not actionable as a matter of law. Although McKichan addresses the narrow issue of the liability of professional hockey players, the court's opinion is consistent with a majority of recent cases that have denied recovery to injured sports participants, whatever their level of skill, and it illustrates the more general problems courts face when trying to gauge whether a sports participant has crossed the line dividing enthusiastic competitors from the malfeasant.

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