The hazards of golf are quite well known, as is the duty of yelling “fore” when an errant shot is struck. But what about the peril of being struck by a club member’s vehicle as you put your spikes on in the parking lot?

In Adler v. Lewis (Supreme Court, Queens County) Justice McDonald exonerated the Fresh Meadows Country Club from liability, finding that the club had neither actual nor constructive notice of club member Lewis’s erratic driving behavior. Perhaps plaintiff should have proceeded on a Dram Shop theory — as opposed to a claim that Fresh Meadows knew or ought to have known that Lewis had difficulty navigating in the confines of the club parking lot.