A liability expert is needed as to the negligence of a referee in an organized league.

The plaintiff’s complaint was dismissed for failure to provide a liability expert report. The defendant filed an in limine motion to dismiss the plaintiff’s complaint because the plaintiff was unable to establish a standard of care or cause of action without an expert report. The court found that an expert report was needed because the allegations were made against the league organizer, who occupies a different position than an opposing player in a game. A jury cannot supply the standard to an organization, how it should be set up and run, and how a referee should determine red or yellow cards. This case distinguishes Crawn v. Crampo, 136 N. J. 494, which involved an informal pickup softball game in which the players set their own rules.

_{Case Law Alerts, 4^th Quarter, October 2016. Case Law Alerts is prepared by Marshall Dennehey Warner Coleman & Goggin to provide information on recent developments of interest to our readers. This publication is not intended to provide legal advice for a specific situation or to create an attorney-client relationship. Copyright © 2016 Marshall Dennehey Warner Coleman & Goggin, all rights reserved. This article may not be reprinted without the express written permission of our firm.}