Rogers v. Professional Golfers Association of America

Linda Rogers (plaintiff) attended the first two days of a championship golf event that was sponsored by the Professional Golfers Association of America (PGA) (defendant) at the Valhalla Golf Club in Louisville, Kentucky (club) (defendant). Louisville experienced a rainstorm on the first day of the tournament, which left the grounds wet and muddy even on the tournament’s second day. Rogers had played some golf over the preceding 10 years and knew that golf courses have differing terrains and conditions. Rogers also knew that a significant amount of rain had fallen on the course on the first day of the tournament. After the tournament’s first day, Rogers exited the club without walking through the course’s grassy and hilly rough because Rogers received special permission to walk through a ticket-restricted pathway without a ticket; Rogers was allowed to do so because she previously had knee surgery. However, on the second day, a security guard denied Rogers permission to walk through the ticket-restricted pathway to the seventeenth and eighteenth holes to watch more of the tournament. Rogers decided to walk to the seventeenth hole via the grassy, hilly rough. According to Rogers, the grass was dry, but, unknown to her, the ground underneath the grass was wet and slippery. However, Rogers could see that the rough was hilly and the grass was matted. Rogers slipped and fell, injuring her leg. Rogers sued the PGA and the club, alleging that the PGA and the club were negligent because they failed to warn her about the hidden hazard posed by the wet ground. Rogers further argued that even if the hazard was open and obvious, the PGA and the club nevertheless failed to exercise ordinary care because they had reason to believe that spectators would walk on the wet, grassy area despite the risk of doing so. The trial court granted summary judgment to the PGA and the club. Rogers appealed.