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Professional sports operates at a higher level than college sports, but these athletes are more likely to face legal action. Dale Hackbart of the Denver Broncos attempted to block Charles Clark of the Cincinnati Bengals during an interception by throwing himself on the ground in front of Hackbart. Hackbart, out of frustration, hit Clark with his right forearm on the back of the neck. The force of the blow was so powerful both men fell to the ground. Three of Clark's vertebrae were broken in the assault.

The United States District Court for the District of Colorado interpreted the incident as an "involuntary reflex," stating,"The violence of professional football is carefully orchestrated. Both offensive and defensive players must be extremely aggressive in their actions, and they must play with reckless abandonment of self-protective instincts." They also pointed out that the only disciplinary actions available in the game were penalties...
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