Pickel v. Springfield Stallions 

Plaintiff, a spectator during arena football game, was injured when football player ran out of bounds, fell over a wall separating spectators from field, and collided with Plaintiff. Because Plaintiff was a spectator, not a participant, doctrine of primary assumption of risk is inapplicable, and Defendants owed her duty of care to take reasonable precautions for safety, such as adequately sturdy wall, or warnings. Defendants not foreclosed from pleading contributory negligence, which is a question of fact for jury.