Charleston, S.C. (April 25, 2025) - The National Golf Course Owners Association (NGCOA), the trade association dedicated exclusively to golf course ownership and operations, is pleased to share a significant legal win for Cazenovia Golf Club (CGC), one of its nearly 4,000 members. After a five-year long battle, and a recent appeal in the New York State Court of Appeals, the Court issued a unanimous decision stating that the club is not liable for injuries sustained by a golfer who was struck by an errant golf ball while playing the course.
As background, a 2020 lawsuit claimed Cazenovia Golf Club, a 99-year old public course, was negligent in the operations of its facility, resulting in a golfer being struck while playing in a tournament. The plaintiff claimed that CGC's poor tee placement created an extremely dangerous situation, and suggested a remedy that called for the installation of a netting system on the fairways — a costly and unnecessary solution which would alter the course design, increase liability concerns nationwide, and set a precedent for the industry.
The plaintiff won his case in the lower court, and Cazenovia Golf Club appealed the decision to the Appellate Division of the New York State Supreme Court. NGCOA submitted an amicus brief with the court on behalf of the golf industry and Cazenovia Golf Club, and in March, NGCOA CEO Jay Karen attended the oral arguments at Broome County Courthouse. The final verdict is the result of this most recent hearing, and reinforced the long-standing legal principle of "assumption of risk" in recreational sports, especially golf.
”We certainly feel for the injured golfer in this case, as no course owner or operator wants to see a customer get hurt” said Karen. “And yet it was important to NGCOA to defend Cazenovia, so that the inherent and attractive elements of the game and fields of play could be preserved. Our game - played over wide acreage, among natural elements, with specific lines of play and including players of all skill levels - involves minuscule chances for accidental injuries to happen. This decision upholds the balance between the assumed risks of play and a golf course owner’s role in maintaining a proper environment for play. It’s a real win for the golf course industry.”
"We are pleased with the Court's decision, which represents a significant victory for Cazenovia Golf Club and, importantly, golf course owners and operators across the United States," says the Board of Directors for Cazenovia Golf Club. "This ruling underscores that golf course owners should not be held liable for the inherent risks of the game and protects the industry from unreasonable burdens. We are grateful to NGCOA for their support in our defense."
As the only trade association dedicated to golf course ownership and operations, the NGCOA supports its members as they navigate and battle legal issues like this one. The association is grateful to its golf course and industry supplier members and supporters whose contributions to the NGCOA Champions Circle allow NGCOA to defend members and industry in the courtroom as well as the halls of government.
About the National Golf Course Owners Association
The NGCOA is the leading authority on the business of golf course ownership and management. The association represents and promotes the interests of golf courses as the principal businesses and economic assets of the game of golf. The not-for-profit organization is the only trade association dedicated exclusively to golf course owners and operators. Through advocacy, education and information resources, purchasing programs and networking opportunities, the NGCOA helps golf course owners and operators run more successful businesses. For more information or to join, visit ngcoa.org or call 800-933-4262.
Media Contact: Renée Flowers, Senior Director of Marketing and Communications, NGCOA, rflowers@ngcoa.org.