Court of Appeals Update - April 2025: Premises Liability on the Golf Course
- Reza Yassi
- 7 days ago
- 3 min read
Updated: 6 days ago
Quick Answer
The Court basically said golf courses don't need to warn people about stuff that's obviously part of playing golf, and tossed out a negligence claim where someone got hit by a stray ball.
Decision at a Glance
Decision: David Katleski v. Cazenovia Golf Club, Inc. — Court of Appeals — 2025 NY Slip Op 02142 — decided April 15, 2025.
Facts: Katleski got nailed by a golf ball from another fairway and tried to sue the club, saying they screwed up the course design and should have warned golfers about getting hit by stray balls.
Procedural Posture: Lower courts sided with the golf club, basically saying "dude, getting hit by golf balls is just part of golf."
Holding: Court agreed and kept the dismissal. They said there's no duty to warn people about common golf hazards that anyone can see coming, and golfers basically sign up for the risk of getting smacked by stray balls when they play.
Full Opinion: Read the full opinion here
Why This Case Matters
This decision really hammers home that places like golf courses don't have to warn people about risks that are just part of the activity. If you're trying to sue recreational facilities, you're going to have a much tougher time proving negligence for stuff that's just inherently part of what you signed up for.
Client Question
"I got hurt playing tennis at a club when I slipped on the court. Can I go after the club for not warning me about the slippery surface?"
Your Answer
That's going to depend on the specifics. After Katleski, if whatever you slipped on was obvious or just typical tennis court stuff, the club probably doesn't owe you a warning. But if there was something weird, hidden, or the result of them not maintaining the court properly, you might actually have something. The key is showing actual negligence, not just that tennis can be risky.
FAQs
What exactly is an "open and obvious" risk?
Something that's right there for everyone to see and that people doing the activity would normally expect to deal with.
Can I still get money if I was partly at fault?
Does assuming the risk mean I can never win?
Action Steps & Key Takeaways
Take pictures and document exactly what the scene looked like right after you got hurt (photos, witness statements, everything).
Try to find out about facility maintenance records and whether other people have complained about similar issues.
Get to an attorney quickly to figure out if what happened was truly just part of the activity or if someone actually screwed up.
Next Steps
If you got injured during recreational activities, document absolutely everything and give us a call to figure out if you've got a real negligence claim worth pursuing.
Reza Yassi, Esq.
Admitted: NY, NJ, Federal Courts
📞 (646) 992-2138 · 📧 ry@yassilaw.com · 🌐 yassilaw.com
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