In 1913, the Kansas City Court of Appeals ruled that spectators who are hit by foul balls cannot sue for their injuries because such occurrences are an inherent part of the game of baseball. See Crane v. Kansas City Baseball & Exhibition Co., 153 S.W. 1076 (Mo. Ct. App. 1913). This decision is the basis for today’s “baseball rule,” a defense recognized in nearly every jurisdiction.
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