In Biggin v. Stark (Aug. 26, 1994), 11th Dist. No. 93-T-4952, 1994 Ohio App, while the parties were playing golf together, the appellant was standing on a cart path next to the tee, and the appellee was taking practice swings. Appellee's golf club slipped out of his hand, flew through the air, and struck appellant in the mouth, causing injury. This court applied a recklessness standard and stated that "since the appellee did not intend the initial act of losing control over the club, it is not possible for the appellee's activity to be defined as reckless."