American Golf Corp. v. Superior Court

Opinion

GRIGNON, Acting P. J.

An errant shot by a golfer ricocheted off a wooden yardage marker, injuring a companion golfer. We conclude the injured golfer’s personal injury action against the golf course for negligent design and placement of the yardage marker is barred by the primary assumption of the risk doctrine. We hold golf is an active sport, errant shots are an inherent risk of golf, yardage markers are an integral part of the sport, and the golf course as recreation provider did not increase the risk of injury by its design and placement of the yardage marker. We grant the golf…