It's a staff problem more often than not. Sure, kids fall down and get hurt playing games at recess. And if the school has taken the basic precautions they ought to take, like having a nurse on staff and some aides on the playground to keep an eye on things, then they aren't going to be found liable for that.
But say the kid breaks his nose on a Wednesday, and Wednesday is the day that the school doesn't have a nurse because they cut the position to part time. Or he broke his nose tripping over a junked piece of equipment, which was clearly dangerous to have out in the middle of the ballfield but it hadn't been moved because the maintenance workers only come out once a month. And maybe the game really was rougher than it should be, and older kids or neighborhood kids were involved who had no business being on the playground, but this went unnoticed because there was only one playground aide and she was clear across the property. Now a judge is going to hold the school partially responsible, as well they should in my opinion.
It's sad. Kids need to play, but they need a safe place to do so, and unfortunately shortages of money and staff make that impossible in many places. It totally sucks for the kids.