There have been several recent stories about on-the-field or on-the-court incidents during sporting events.  See Youth Coach Attacks Opposing Player; Temple Coach John Chaney Sends "Goon" To "Send A Message," Miami v. Florida International, etc. 

In Brokaw v. McSorley, Adv. No. 05-31213, 2006 Bankr. LEXIS 2728 (Bankr. S.D. Iowa October 18, 2006), the debtor was a high school basketball player who, according to game films, through a haymaker fist or elbow on an opposing player during the course of a game.  The film showed that before this incident, the debtor had also undercut an opposing player during a layup, and threw an elbow that missed at another opposing player.  In the incident at issue in the case, both players were away from the action, and the debtor’s move was not, the Judge found, an attempt to get free from the defense or otherwise a part of the game.

The injured player sued, and the debtor filed his Bankruptcy petition.  The Judge reviewed the game films and held that the debtor’s actions were maliciously targeted at the injured player and certain to cause him harm.  In reaching this conclusion, the court considered the prior conduct of the debtor during the game and the fact that the debtor’s team was losing badly.  While not required, the Court also found that the actions showed the presence of "spite, ill will or personal animosity." 

The Court concluded that any damages awarded b the state court (after the stay was lifted) would be non-dischargeable pursuant to §523(a)(6).