Allen v. Donath

According to the Ohio Supreme Court in Thompson, “a player who injures another player in the course of a sporting event by conduct that is a foreseeable, customary part of the sport cannot be held liable for negligence because no duty is owed to protect the victim from that conduct.”1 I find this description of the scope of the reckless conduct standard to be more practical than the distinction between contact and non-contact sports. Although golf is not a contact sport in the same sense as football, ice hockey, or polo, a golfer obviously accepts the risk of *441coming in contact -with wayward…