A court has found that State Farm need not pay for the medical care required by Patrick Frake after his friend John King punched him in the testicles. The California Second Appellate Division found that Frake and King had made a long habit of getting drunk and punching each other in the balls, and that this habit meant that the injury wasn't an "accident," and thus wasn't covered by Frake's insurance.
During this 'consensual' ritual, one person would normally try to 'slap or hit [another person] in . . .the groin area,' and the recipient would then 'attempt to return [the slap or hit].' According to Frake, the practice was so common that his friends would 'greet each other with a one-arm hug,' while covering their 'groin area' with the other arm for 'protection in case [someone] decided to . . . instigate th[e] horseplay." Frake stated that [he] and his friends had, 'per usual,' been engaging in 'horseplay . . . [that] continued throughout the whole weekend."