“Plaintiff claims he was harmed by Defendant’s [coaching/training/instruction]. To establish this claim, Plaintiff must prove all of the following: 1. That Defendant was Plaintiff’s [coach/trainer/instructor]; 2. That Defendant intended to cause Plaintiff injury or acted recklessly in that his conduct was entirely outside the range of ordinary activity involved in teaching or coaching [sport or other recreational activity, e.g., horseback riding] in which Plaintiff was participating or That Defendant unreasonably increased the risks to Plaintiff over and above those inherent in [e.g., horseback riding]; 3. That Plaintiff was harmed; and 4. That Defendant’s conduct was a substantial factor in causing Plaintiff’s harm.”
[CACI Jury Instructions [citations omitted]]
