In Kimbar v. Estis, 1 NY2d 399, 135 N.E.2d 708, 153 N.Y.S.2d 197 (1956), a young camper had wandered off a camp path at night and hit a tree.
The Court found that the camp owners had no duty to illuminate the path in the absence of any particular danger on the path, finding:
We have before us a simple camper-camp relationship and the rustic, outdoor camp life that is the very raison d'e tre of summer establishments such as defendants'. There are certain risks incidental to camping, but these are part of an adventurous summer camp life, and are necessarily assumed by those who would participate therein . . .
Indeed, it is expected that a camp will have trees, that paths will lead through woods and that woods will be dark at night. It is not to be anticipated that floodlights will be supplied for campers through woodland paths. One naturally assumes many ordinary risks when in the woods and in the country trails are not smooth sidewalks, paths are not paved, trees, brush and insects are to be expected, and even snakes may appear occasionally. These and more are all a part of accepted camp life.
To hold summer camps to a duty of floodlighting woods would not only impose upon them a condition almost impracticable under many circumstances but would be unfair, as well, to the youth who seek the adventure of living closer to nature, participating in outdoor astronomical study at night or bird study before dawn, or when overnight hikes take them for study and adventure far from any source of electrical power. Such a duty, in short, would frequently compel camps to keep boys confined after dark and thereby effectively spell the end of some of the most desirable activities of real camping life.