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Koffman v. Garnett

Supreme Court of Virginia
574 S.E.2d 258 (Va. 2003)

Koffman v. Garnett


When he was 13 years old, Andrew Koffman (Andrew) joined a football team. He had never played football before. Early in the season, the team’s assistant coach, James Garnett (defendant), criticized the boys’ tackling skills. Garnett then commanded Andrew to hold a football and to stand upright, motionless. Garnett lifted Andrew at least two feet off the ground and slammed him down. Andrew weighed approximately 144 pounds; Garnett weighed 260. The force of Garnett’s throw broke Andrew’s arm. Prior to the incident, coaches had never used physical force as a form of instruction. Andrew’s parents, Richard and Rebecca Koffman (plaintiffs), individually and on behalf of Andrew, sued Garnett in a Virginia court for gross negligence, assault, and battery. The trial court dismissed the complaint. The Koffmans appealed.

Rule of Law


Holding and Reasoning (Lacy, J.)

Concurrence/Dissent (Kinser, J.)

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