Governmental immunity from liability for injuries on recreational trails does not shield a city from liability for injury from errant golf balls hit from an adjoining commercial golf course on city property. Gov. Code 831.4 grants governmental entities immunity from liability for injuries suffered on unpaved paths or trails. Even if the paved Rose Bowl Loop in Pasadena qualifies as a trail for purposes of this section, Pasadena is not immune from liability for injuries a pedestrian on the trail suffers as a result of an errant golf ball hit from an adjoining, city-owned golf course. The golf course was a commercially operated, revenue-generating operation that exposed other people to the risk of injury from errant golf balls, and it was the defective condition of the golf course, not the path, that caused plaintiff’s injury.
California Court of Appeal, Second District, Division 2 (Ashmann-Gerst, Acting P.J.); May 3, 2017; 2017 WL 1684205