Who Is Liable If You Fall from the Back Passenger Seat of a Golf Cart?

Published 06 May.2026 15:13(KST)

Recent Rulings on Various Golf Course Accidents

As the spring golf season gets underway, more people are visiting golf courses, but related safety accidents continue to occur. Focusing on court rulings delivered over the past two months, we examine the judiciary’s decisions regarding golf course safety incidents, including cart falls, ball-striking accidents, and powder room slip injuries.

Golf ball. Pixabay

Recent Rulings on Accidents During Rounds

The courts acknowledge that golf course operators have a duty of care to safely manage their facilities, and that caddies also bear a duty of care to monitor and guide golfers for their safety during play. Notably, the courts also find that golfers themselves have a responsibility to take precautions for their own safety.

① Struck by a Ball Hit by a Golfer from the Previous Group

At around 5:00 p.m. in July 2022, plaintiff A began a round at a golf course with a colleague. Plaintiff A was waiting 40 meters in front of the green on the 7th hole. Defendant B, who was playing in the preceding group, took a tee shot from the 8th hole teeing ground. However, the ball struck by defendant B flew toward the 7th hole and hit plaintiff A in the face. As a result, plaintiff A suffered injuries including a left orbital wall fracture, traumatic hyphema, and retinal concussion.

At the time, caddy C assisted plaintiff A, while caddy D assisted defendant B. Defendant E is the company that operates and manages the golf course. Plaintiff A filed a lawsuit against the defendants.

On March 11, the Cheonan branch of the Daejeon District Court partially ruled in favor of the plaintiff, stating, "The defendants are jointly ordered to pay plaintiff A approximately 60.4 million won" (2023Gadan106913).

The court stated, "Golfers must always be vigilant and carefully observe the direction in which the ball could possibly travel, as the ball may deviate from their intended path." The court also pointed out that defendant B had just finished the 7th hole before teeing off from the 8th, and thus was well aware of the positions, structures, distances, and topographical features of both holes. The court held, "Defendant B violated the duty of care by hitting the ball without checking whether anyone was within the possible range of the ball's trajectory, resulting in the ball flying toward the 7th hole."

The court also found that caddies C and D were aware of the course’s topographical characteristics. Furthermore, △caddy D, who assisted defendant B, had a duty to check the status of play on the 7th hole, guide the group including plaintiff A to safety before allowing defendant B to tee off, or at least warn the group on the 7th hole that a ball was about to be hit; △caddy C, who assisted plaintiff A, had a duty to check the status of play on the 8th hole and prevent any member of the preceding group from teeing off, or at least guide plaintiff A and the other members of the trailing group to a safe location. The court found that both caddies failed to fulfill these obligations. The court also recognized the responsibility of defendant E, ruling that "E is liable both as the employer of the two caddies and for failing to install legally required safety facilities."

However, the court limited the defendants' liability to 80%. The court explained, "In golf, balls hit by other participants may travel in unintended directions, so golfers must take care to ensure their own safety, such as checking the direction of the ball when others are hitting. It is difficult to conclude that plaintiff A fully discharged this duty of care. In particular, plaintiff A was not wearing a golf cap at the time of the accident, and had he worn one, the resulting eye injury from the impact may have been avoided."

② Struck by a Ball Hit by a Teammate

In cases where a golfer is hit by a ball struck by a fellow participant, the courts have recognized the negligence of the person who hit the ball.

In September 2024, plaintiff F was playing golf at a course with defendant G and others, when he was struck in the back of the head by a ball hit by defendant G. As a result, plaintiff F suffered injuries including a concussion without an open cranial wound, cervical disc disorder with radiculopathy, and an open scalp wound.

On April 17, the Incheon District Court ruled, "Defendant G must pay plaintiff F approximately 8.3 million won" (2025Gadan209610). The court stated, "Golf participants are obligated to follow the rules of play and remain vigilant to avoid injury. Defendant G is at fault for hitting the ball despite being able to fully confirm that plaintiff F was ahead." However, the court limited defendant G's liability to 70%. The court stated, "Plaintiff F should also have been aware that a ball struck by defendant G could travel in an unexpected direction, and should not have positioned himself in front of the ball’s line at the moment of the shot. Even if ahead, plaintiff F should have moved back or positioned himself outside the anticipated trajectory before the shot, thereby securing his own safety, but failed to do so."

Golf Cart Falls and Artificial Turf Slipping Accidents

There are also cases where golfers fall from moving golf carts or slip and fall after stepping on synthetic mats.

③ Accident Falling from a Golf Cart

In incidents where someone falls from a golf cart, the caddy may be found in breach of duty of care, but the caddy is not always held liable.

In June 2022, at around 12:30 p.m., plaintiff H fell to the ground from the right side of the back passenger seat of an electric cart driven by a caddy at a golf course, suffering an epidural hemorrhage without an open cranial wound. Plaintiff H sued the golf course operator, but on March 4, the Jeonju District Court ruled against the plaintiff (2022Gadan20483). Plaintiff H argued that the caddy failed to reduce speed on a downhill and during left and right turns, and that the accident occurred when the cart made a left turn without slowing down, causing her to be thrown to the ground on the right side.

However, the court found, "According to the accident scene video, the location appears to be on a downhill slope, but the left turn had not yet begun. Therefore, it is difficult to conclude that the accident was caused by the caddy making a left turn at speed as plaintiff H claimed."

④ Slipping Accident on Artificial Turf

There are also lawsuits where plaintiffs claimed to have slipped on a bumpy section where artificial mats were joined together while walking on a downhill section between holes. At around 7:50 a.m. in November 2023, plaintiff J was moving from the 2nd to the 3rd hole at a golf course with companions when he slipped and suffered injuries including a lateral malleolus fracture, closed injury, and ligament tears in the ankle and foot. Plaintiff J sued both the golf course operator and insurance company K, which had entered into a liability policy for sports facility operators. However, on April 9, the Ulsan District Court ruled against the plaintiff (2025Na11078).

The court acknowledged that the accident site was on a downhill slope and the artificial mat finishing was incomplete. However, it did not find a violation of the golf course operator’s duty of care. The court explained, "△There is insufficient objective evidence to confirm the site’s condition or any level differences at the time of the accident; △the photos alone do not conclusively establish a fall risk due to elevation differences; △on the day of the incident, the minimum temperature was between -1.7°C and 0.7°C, and since the accident occurred around 7:50 a.m., plaintiff J could have reasonably anticipated slipperiness due to frost; △plaintiff J was a member who used the course about twice a week and was familiar with the conditions and terrain. These factors were considered comprehensively."

⑤ Slipping While Putting on Shoes in the Powder Room

There was also an accident that occurred in a powder room.

In October 2024, after finishing a round and taking a shower, plaintiff L slipped and fell while attempting to put on shoes at the entrance to the powder room, where the shoe rack ledge was made of slippery marble. As a result, plaintiff L suffered a distal right radius fracture and argued that defendant M, the golf course operator, failed in its safety obligations by not using slip-resistant materials, not installing anti-slip ledges, and not posting warning signs. However, on April 8, the Busan District Court ruled against the plaintiff (2025Gadan47480).

The court found, "The entire powder room floor is made of wood, and only the end of the powder room and the shoe rack floor are marble. It is common to use marble at the entrance ledge and floor of shoe racks in residential apartments or public facilities." The court continued, "Plaintiff L fell at the marble shoe rack ledge while trying to put on shoes at the powder room entrance, not the shower entrance. In other words, the shoe rack ledge in question is beyond the wooden powder room, and it does not appear that water from the shower made the shoe rack ledge or the users’ feet wet. Plaintiff L did not claim there was any water on the marble, and given the unclear circumstances of the fall, it cannot be established that defendant M’s facilities lacked typical safety or that M failed in its management duties."