Court of Appeals Update – April 2025: Premises Liability on the Golf Course
- Reza Yassi
- Jun 5, 2025
- 3 min read
Updated: Feb 19
The New York Court of Appeals has clarified that golf courses generally do not owe a duty to warn players about risks that are open, obvious, and inherent to the game of golf. This decision has important implications for New York golf course premises liability claims, particularly where injuries result from known hazards like stray golf balls.
Case Overview: Katleski v. Cazenovia Golf Club, Inc.
Court: New York Court of Appeal
Citation: 2025 NY Slip Op 02142
Decision Date: April 15, 2025
Facts
David Katleski was injured when a golf ball from another fairway struck him. He argued that the course was negligently designed and that the golf club failed to warn participants of the risk of stray balls.
Procedural History
Lower courts dismissed the case, concluding that being struck by a golf ball is a common, inherent risk of playing golf.
Court’s Holding
The Court of Appeals affirmed dismissal. Golf courses are not required to warn against open and obvious risks. Golfers assume these risks when participating in the sport.
Implications for New York Premises Liability
This ruling reinforces the principle that recreational facilities are not insurers of safety. However, there are exceptions. A skilled premises liability lawyer New York can help determine if your case involves actionable negligence, such as:
Unsafe conditions unrelated to the sport
Poor maintenance or defective equipment
Hidden hazards not obvious to a reasonable participant
When You May Still Have a Claim
Even after this decision, injuries caused by negligent conditions may still give rise to legal claims. A personal injury lawyer New York can evaluate situations where the property owner may have failed to meet their duty of care.
For example, if a golf club failed to maintain barriers or properly manage the course layout, you may have grounds for a claim. Similarly, injuries caused by defective or slippery surfaces could fall outside the assumption-of-risk doctrine.
Client Question: “Can I Sue After a Recreational Injury?”
It depends. Injuries resulting from obvious, inherent risks are generally not compensable. However, injuries caused by hidden dangers or negligence may still allow for recovery.
It’s important to consult an accident attorney NYC promptly to preserve evidence and evaluate your legal options. Experienced New York accident lawyers and a personal injury lawyer Brooklyn can determine whether your injury resulted from negligence rather than an assumed risk.
FAQs
What is an “open and obvious” risk?
An open and obvious risk is a condition that a reasonable person participating in the activity would be aware of, such as stray golf balls or common hazards in sports.
Does assumption of risk prevent all recovery?
No. Assumption of risk does not bar claims for concealed or unexpected dangers or negligent maintenance.
Can I recover if I was partially at fault?
Yes. New York follows comparative negligence rules, so partial fault does not automatically prevent recovery.
Who should I contact after an injury?
If you are injured at a recreational facility, speak with an accident attorney NYC, personal injury lawyer Manhattan, or one of the experienced New York accident lawyers to understand your legal rights.
What to Do After a Recreational Injury
Take photos of the scene and the hazardous condition.
Collect witness statements.
Report the incident to the facility.
Request maintenance or incident records.
Contact a qualified personal injury attorney New York or premises liability lawyer New York immediately.
Key Takeaways
Golf courses are generally not liable for risks inherent to the sport.
Hidden dangers or negligent maintenance may still create a claim.
Early consultation with a premises liability lawyer New York or personal best injury lawyer New York is crucial to protect your rights.
Next Steps
If you or a loved one were injured during a recreational activity in New York, documenting the scene and seeking legal guidance from personal injury lawyer Manhattan or New York accident lawyers is critical. Determining whether negligence occurred versus assumed risk will dictate your ability to pursue compensation.
Conclusion
The information provided in this blog is for general informational purposes only and does not constitute legal advice. Reading this content does not create an attorney-client relationship. For advice regarding your specific situation, please consult a qualified personal injury lawyer New York or premises liability lawyer New York.
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