In Rinaldo v. McGovern, 78 N.Y.2d 729, 587 N.E.2d 264, 579 N.Y.S.2d 626 (N.Y. 1991), the New York court recognized that merely because a golf ball does not travel in the intended direction does not establish a viable negligence claim. There, the errant shot broke the windshield of a car traveling on a road adjacent to the golf course. The New York court applied traditional tort liability requirements that there must exist a recognizable risk and a basis for concluding that the harm following from the consummation of the risk was reasonably preventable. The court concluded that the game of golf is such that the risk of a mis-hit golf ball is not a fully preventable occurrence. In other words, the court said the risk was foreseeable, but not preventable. Id. at 267.