According to TMZ, Shaun Ellis, a defensive lineman for the New York Jets, has been sued for throwing a snowball at a Seahawks fan after a 13-3 loss in 2008.
As per the video below, it appears that Seattle fans threw several snowballs at the Jets players as they were walking through the tunnel. Ellis is then shown picking up a large chunk of snow and throwing it at a fan in the stands. The fan seemed quite happy to be the target and held it in celebratory fashion.
The Seahawks fan, and Plaintiff in this case, Robert Larson, claimed that he "suffered physical injury, humiliation, mental distress, pain and wage loss from the incident." Larson also claimed that he had been waving a Seahawks sign, making him a "perfect snowball target".
If the fan had thrown snowballs at Ellis, the lineman could claim self-defence.
No word on whether Jets fans generally can sue for pain and suffering as a result of their team's past performance.
Here's the video clip of the incident: