https://motherboard.vice.com/en_us/article/ne5478/protecting-golfers-from-wasps-is-part-of-a-golf-courses-duty-rules-california-court

A California woman who sued a golf course after she nearly died from being attacked by wasps on the greens had some success this week. In an appeal, a court has ruled that property owners, including golf courses, have a “duty” to protect patrons from dangerous insects on their property.

In July 2013, Carolyn Staats was taking a private golf lesson at Vintner’s Golf Club in Napa Valley. While teeing up at the fifth hole, she was suddenly swarmed by dozens of yellow jackets—a predatory social wasp that has black and yellow stripes and is really nasty.