What is the central rule in Hudson v. Craft?

A promoter of an unlicensed boxing match can be liable for injuries to participants even if they consented to fight.

Does consent protect the promoter?

No. When the event is illegal, consent by fighters does not shield the promoter from liability.

Why is this case linked to volenti non fit injuria?

The maxim does not apply to excuse a promoter running an unlawful match; the law prioritizes safety and licensing rules.

Does the fighter’s age matter?

Yes. The plaintiff was a minor, strengthening the view that consent could not legalize the dangerous, illegal event.

What practical lesson does the case teach?

Promoters must follow licensing laws; running illegal contests risks tort liability despite participants’ consent.

Hudson v. Craft (Volenti Non Fit Injuria)

Tort Law 204 P.2d 1 1949 (decision), Published: 30 Oct 2025 California Supreme Court Gulzar Hashmi ~5 min read

PRIMARY_KEYWORDS: volenti non fit injuria, illegal boxing, promoter liability SECONDARY_KEYWORDS: consent, licensing, minor, tort damages

Quick Summary

A carnival ran unlicensed boxing bouts. A teenager fought, got hurt, and sued the promoter. The court held: in an illegal boxing match, the promoter can be liable even if fighters consent. Licensing laws exist to protect people; consent cannot make an unlawful event safe or legal.

Citation: Hudson v. Craft, 204 P.2d 1 (Cal. 1949)

Issues

Is the promoter of an illegal event liable for injuries suffered by participants who consented to fight?

Rules

A boxing promoter is liable for injuries in an unlicensed match, even if the boxers consent.

Where safety statutes apply, consent does not defeat liability for those who violate the law.

Facts (Timeline)

Timeline for Hudson v. Craft facts set at a carnival boxing booth

The defendant ran a carnival featuring a boxing attraction.

Matches violated licensing laws (Penal Code §412 and business licensing rules); prizes and money were offered.

The defendant paid the plaintiff $5 to fight.

The plaintiff, a minor, was injured by an opponent’s blows.

He sued the promoter for injuries, seeking $15,000.

Arguments

Appellant (Plaintiff)

The bout was illegal; safety laws protect fighters, especially minors.
Promoter induced participation and should bear responsibility.
Consent in an unlawful event cannot waive statutory protection.

Respondent (Defendant)

Fighter consented to the match and assumed the risk.
Injuries arose from ordinary incidents of boxing.

Judgment

The California Supreme Court held for the plaintiff. The promoter was liable because the matches were unlawful. Consent by a participant, especially a minor, did not erase the promoter’s duty under safety and licensing laws.

Consent cannot legalize an unlicensed, statutorily prohibited contest.

Ratio

Where statutes regulate dangerous activities to protect participants, volenti non fit injuria does not shield a promoter who breaks those statutes. The duty to comply with licensing is independent of the fighter’s consent.

Why It Matters

Shows limits of consent in illegal sports contests.
Emphasizes statutory duties meant to protect health and safety.
Important for exam problems on volenti and statutory policy.

Key Takeaways

Illegality cancels consent as a defense for promoters.
Licensing statutes create duties that protect fighters.
Minors get extra protection; inducement increases liability.
Promoter liability survives even when participants agree to fight.

Mnemonic + 3-Step Hook

Mnemonic: “ILLEGAL RING? CONSENT WON’T SAVE.”

Check legality — unlicensed = unlawful.
Spot consent — fighter agreed, but law overrides.
Pin liability — promoter broke safety rules.

IRAC Outline

Issue

Is a promoter liable for injuries in an unlicensed boxing match despite the fighter’s consent?

Rule

Violating licensing/safety statutes removes the protection of volenti for promoters.

Application

The carnival paid a minor to fight in an unlicensed bout with prizes. Statutes aimed to protect fighters; consent could not legalize the contest.

Conclusion

Promoter liable for the plaintiff’s injuries; volenti defense fails.

Glossary

Volenti Non Fit Injuria: “To a willing person, no injury is done.” Consent can bar recovery—unless the act is illegal or protected by statute.
Licensing Statutes: Laws requiring permits for risky activities like boxing to safeguard participants and the public.
Promoter Liability: Responsibility of organizers who conduct events in breach of safety or licensing rules.