Although this Court has not spoken on the issue of liability in the context of sports injuries, the lower courts of this state and the high courts of many other states have. Three models of liability have emerged. A majority of courts have adopted a "reckless or intentional" standard in a variety of sports-related situations, requiring an injured plaintiff to prove that the participant-defendant's conduct was either reckless or intentionally injurious. n1 And some courts have extended this standard to situations in which the defendant is a nonparticipant in the sporting event, as the court of appeals determined Southwest Key to be here. See Morgan v. State, 90 N.Y.2d 471, 685 N.E.2d 202, 207-08, 662 N.Y.S.2d 421 (N.Y. 1997) (holding that, in assessing whether an owner or operator of an athletic facility has violated a duty of care toward voluntary participants injured on the premises, the applicable standard should include whether the conditions caused by the defendant's negligence were unique and created a dangerous condition over and above the usual dangers inherent in the sport); Kline v. OID Assocs., 80 Ohio App. 3d 393, 609 N.E.2d 564, 565 (Ohio Ct. App. 1992) (applying the reckless or intentional standard when an injured indoor soccer game participant sued the owner of the facility in which the game was played as well as the organizer of the soccer league). However, a few states adhere to the traditional negligence standard, under which a defendant owes a duty of ordinary care. See Estes v. Tripson, 188 Ariz. 93, 932 P.2d 1364, 1366 (Ariz. Ct. App. 1997); Auckenthaler v. Grundmeyer, 110 Nev. 682, 877 P.2d 1039, 1043-44 (Nev. 1994); Lestina v. W. Bend Mut. Ins. Co., 176 Wis. 2d 901, 501 N.W.2d 28, 32-33 (Wis. 1993). Finally, there is the "inherent risk" standard, previously advocated by some MEMBERS of this Court, which states that both co-participant and nonparticipant defendants owe no duty to protect a participant from risks inherent in the sport or activity in which he has chosen to take part. Phi Delta Theta Co. v. Moore, 10 S.W.3d 658, 663, 42 Tex. Sup. Ct. J. 1029 (Tex. 1999) (Enoch, J., dissenting to improvident grant); see also West v. Sundown Little League of Stockton, Inc., 96 Cal. App. 4th 351, 116 Cal.Rptr.2d 849, 854-55 (Cal. Ct. App. 2002) (applying the inherent risk standard in a suit by an injured little league player against local and national little league organization and coaches); Davis v. Greer, 940 S.W.2d 582, 40 Tex. Sup. Ct. J. 62, 582-83 (Tex. 1996) (Gonzales, J., opinion on denial of application for writ of error) (arguing that the inherent risk standard is preferable to the reckless or intentional standard); Scott v. Pac. W. Mountain Resort, 119 Wash. 2d 484, 834 P.2d 6, 13-14 (Wash. 1992) ("A defendant simply does not have a duty to protect a sports participant from dangers which are an inherent and normal part of a sport.").