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Richard v. Mangion

Citations: 535 So. 2d 414; 1988 La. App. LEXIS 1769; 1988 WL 85427Docket: No. 87-636

Court: Louisiana Court of Appeal; August 18, 1988; Louisiana; State Appellate Court

Narrative Opinion Summary

In this case, the plaintiffs, parents of a minor, appealed a judgment dismissing their lawsuit against another minor's guardians and an insurance company, following an altercation between the two boys. The primary legal issue revolved around whether the plaintiffs' son, Shawn, voluntarily participated in a fight with Jeremy, the defendants' son, at a location known as the 'rope swing.' Despite conflicting testimonies, the trial court found that both boys willingly engaged in the fight, and no excessive force was used, thus limiting Shawn's recovery for injuries under the defense of consent. The court noted that the principle of consent to an intentional tort restricts recovery unless excessive force is used, and determined that the fight involved no weapons, with both participants being similarly matched in size. The appellate court affirmed the trial court's judgment, ruling that the findings of fact regarding voluntary participation and the use of reasonable force were not clearly erroneous. Consequently, the costs of the appeal were assessed against the plaintiffs-appellants, upholding the dismissal of their suit.

Legal Issues Addressed

Consent as a Defense to Battery

Application: The court applied the legal principle that consent to an intentional tort limits recovery unless excessive force is used. In this case, consent was not negated by peer pressure or the sequence of blows.

Reasoning: Consent remains valid even if one party strikes first or if blows are not simultaneous.

Consent to Engage in a Fight

Application: The court determined that by arriving at the rope swing prepared to fight, Shawn impliedly consented to the altercation, and thus limited his ability to recover damages for injuries unless excessive force was used.

Reasoning: Shawn understood that going to the rope swing implied his consent to engage in a fight.

Standard of Review for Findings of Fact

Application: The appellate court upheld the trial court's findings of fact, emphasizing that such findings are not easily overturned unless they lack a sufficient basis or are clearly wrong.

Reasoning: The court established that findings of fact regarding voluntary participation and the use of reasonable force are not easily overturned unless they lack sufficient basis or are clearly wrong.

Voluntary Participation and Use of Force

Application: The trial judge found that both boys were willing participants in the fight and did not use excessive force, which influenced the court's decision to dismiss the suit.

Reasoning: The trial judge determined that while Jeremy instigated the encounter, both boys were willing participants and did not use excessive force.