New York Court of Appeals

Katleski v. Cazenovia Golf Club, Inc.

April 15, 20252025 NY Slip Op 02178

Summary

The court held that primary assumption of risk barred Katleski's negligence claim because being struck by a mishit golf ball was inherent in golf and the evidence did not show that the course design unreasonably enhanced that risk. It held that the doctrine did not bar Galante's claim because she was injured while driving a golf cart in a parking lot before participating in golf. Katleski's judgment was affirmed, while Galante's judgment was reversed and remanded for consideration of unresolved issues.