## Facts

- Linda A. Rogers attended the 1996 PGA Championship at Valhalla Golf Club in Louisville, Kentucky, as a spectator.
- A rainstorm occurred on the first day of the tournament; the course remained wet and muddy in places on the second day.
- Rogers had prior experience with golf courses and knew it had rained the previous day.
- A nearby “tent village” provided an alternate route to the main entrance, but access required a special ticket.
- On the first day, due to a prior knee surgery, Rogers received special permission to pass through the tent village to avoid a grassy hillside near the seventeenth fairway.
- On the second day, a security guard denied Rogers access through the tent village because she lacked the required ticket.
- Rogers chose to traverse the grassy, sloped rough area; she observed it was hilly and that the grass was matted, but believed the grass appeared dry.
- Rogers slipped and fell on the hillside, injuring her leg.
- Rogers sued the PGA and related Valhalla entities for negligence, primarily alleging failure to warn of a “hidden hazard” from wet ground beneath the grass.

## Issues

1. Whether the defendants owed an invitee-spectator a duty to warn or protect against the risk of slipping on a wet, grassy hillside following rain where the condition was alleged to be open and obvious.
2. Whether an exception to the open-and-obvious rule applied because the defendants should have anticipated that spectators would encounter the hazard despite its obviousness.
3. Whether summary judgment was proper on duty and breach under Kentucky premises-liability law.

## Decision

- The Kentucky Court of Appeals affirmed summary judgment for all defendants.
- The court held the wet, sloping grassy hillside presented an open and obvious condition to a reasonable spectator under the circumstances.
- The court rejected the claim that wetness beneath seemingly dry grass converted the condition into a concealed hazard.
- The court concluded the defendants had no duty to warn or take additional protective measures for this natural outdoor condition, and no facts triggered the foreseeability-based exception to the open-and-obvious rule.

## Legal Principles

- A land possessor owes invitees a duty of ordinary care but generally has no duty to warn of conditions that are known or obvious to the invitee.
- Under Restatement (Second) of Torts § 343A principles, a duty may still exist for an obvious danger if the possessor should anticipate harm despite the invitee’s awareness; application depends on the facts.
- Visible natural terrain and weather-related conditions in an outdoor recreational setting (e.g., wet grass on a slope after rain) are typically treated as risks a reasonable invitee is expected to recognize and avoid, absent additional circumstances creating a special duty.

## Conclusion

The court affirmed dismissal of the spectator’s negligence claim because slipping on wet, sloped grass after a known rain was an open and obvious risk, and the record did not support imposing a duty on the tournament and venue operators to warn or otherwise protect against that condition.


Rogers v. Pro. Golfers Ass’n of Am., 28 S.W.3d 869 (Ky. Ct. App. 2000)