Points of No Return: How the Ninth Circuit's New Voluntary Undertaking Doctrine Changes Return-to-Play in Sports.

The article discusses the U.S. Ninth Circuit Court of Appeals interpretation of the voluntary undertaking doctrine has changed return-to-play policies in sports. Topics covered include its decisions in Mayall v. USA Water Polo and Dent v. National Football League, how the application of the voluntary undertaking doctrine has shifted following the decisions, and the new interpretation of negligence liability for over-seeing athletic organizations shared by the two cases.