American Golf Corp. v. Superior Court

In American Golf Corp. v. Superior Court (2000) 79 Cal.App.4th 30, a golfer was injured when an errant shot ricocheted off a wooden yardage marker. Although the trial court denied defendant's motion for summary judgment, Division Five of the Second District issued a writ of mandate directing the court to grant the motion. The appellate court held that "golf is an active sport to which the assumption of the risk doctrine applies. . . . 'Hitting a golf ball at a high rate of speed involves the very real possibility that the ball will take flight in an unintended direction. If every ball behaved as the golfer wished, there would be little "sport" in the sport of golf. That shots go awry is a risk that all golfers, even the professionals, assume when they play.' . . . Errant golf shots may strike a fixed object, such as a rock, tree or fence, ricochet, and strike another player." (Id. at pp. 37-38.)