JUSTICE GROMETER delivered the opinion of the court:

Plaintiff, Cheryl Heiden, brought this negligence lawsuit inthe circuit court of Lake County seeking recovery for personalinjuries she allegedly suffered when struck by a golf ball hit bydefendant, Joe Cummings. The trial court entered partial summaryjudgment for defendant on certain allegations of negligence, andthe cause proceeded to a jury trial on the remaining negligenceallegations. The jury returned a verdict for defendant, and thetrial court entered judgment on the verdict. On appeal, plaintiffchallenges the partial summary judgment. We affirm.

The pleadings establish that on May 5, 1999, plaintiff wasplaying golf at a country club in McHenry. As she was playing nearthe 17th green, defendant was preparing to tee off at the 18th tee. Defendant's shot veered off sharply to the left and struckplaintiff's ankle. Plaintiff alleged that defendant's negligence consisted of one or more of the following acts or omissions:

"(a) [Defendant] [d]id not properly swing his clubat the ball so as to hit his ball in the direction of theeighteenth hole where he was aiming;

(b) [Defendant] [f]ailed to maintain a properlookout;

(c) [Defendant] [f]ailed to give warning of hismisguided shot to the Plaintiff, by orally shouting'Fore' or by other means;

(d) [Defendant] [w]as otherwise careless andnegligent in shooting his golf shot as aforesaid directlyat the Plaintiff ***."

At her deposition, plaintiff described her position relativeto defendant with reference to a clock face: defendant was locatedat 6 o'clock, plaintiff was at 8 o'clock, and the 18th hole was at12 o'clock or 1 o'clock. She further testified that she was about25 feet from defendant when his ball struck her. In contrast,defendant testified at his deposition that if he was located at 6o'clock, the pin on the 18th green was at about 12 o'clock, and the17th green was at 7 o'clock. He estimated that he was about 30yards from plaintiff, but acknowledged that he might have beencloser.

Defendant further testified that he was aiming for the 18thgreen, but as soon as he hit the ball, he knew it was a bad shot. He glimpsed the ball veer to the left and strike plaintiff. Hetestified that he could not tell whether he had closed his clubface or hit the ball with the heel of the club. He also testified: "I don't remember every single detail of the shot, and, youknow, where my feet were. Did one of my feet slip? Did myhand twist?"

Defendant moved for summary judgment. The trial court grantedthe motion with respect to the allegations that defendant did notproperly swing his club and was otherwise careless and negligent in making the shot. The matter proceeded to a jury trial at whichthe only negligence allegation at issue was defendant's failure towarn plaintiff of the stray shot. The jury returned a verdict fordefendant, and this appeal followed.

At the outset, we briefly note that defendant has objected to,and asked us to strike, several portions of plaintiff's brief. Suffice it to say, we have examined plaintiff's brief in light ofdefendant's objections and find no meaningful violation of therules governing the preparation of appellate briefs. We thereforedecline defendant's request to strike portions of plaintiff'sbrief.

Turning to the merits, plaintiff contends that the trial courterred in entering a partial summary judgment. Summary judgment isappropriate where "the pleadings, depositions, and admissions onfile, together with the affidavits, if any, show that there is nogenuine issue as to any material fact and that the moving party isentitled to a judgment as a matter of law." 735 ILCS 5/2--1005(c)(West 2000). On a motion for summary judgment, the court may makea summary determination of fewer than all of the major issues inthe case and set the case for trial on the remaining issues. 735ILCS 5/2--1005(d) (West 2000). "Even though a plaintiff is notrequired to prove her case at the summary judgment stage, she mustpresent a factual basis that would arguably entitle her to ajudgment in her favor." Churkey v. Rustia, 329 Ill. App. 3d 239,245 (2002). "A plaintiff may not resist a motion for summaryjudgment, on an issue on which he has the burden of proof, byarguing that it is up to movant to negate his case." Benner v.Bell, 236 Ill. App. 3d 761, 769 (1992).

Applying these principles, we conclude that the trial courtproperly entered partial summary judgment for defendant withrespect to the allegations that he negligently executed his teeshot. It has generally been recognized "the mere fact that aperson is struck by a golf ball driven by one playing a game ofgolf does not constitute proof of negligence on the part of thegolfer who hit the ball." D. Holliday, Annotation, Liability toOne Struck By a Golf Ball, 53 A.L.R.4th 282, 289 (1987). Moreover,we agree with the reasoning in Rinaldo v. McGovern, 78 N.Y.2d 729,587 N.E.2d 264, 579 N.Y.S.2d 626 (1991), where the New York Courtof Appeals observed as follows:

"Although the object of the game of golf is to drive the ballas cleanly and directly as possible toward its ultimateintended goal (the hole), the possibility that the ball willfly off in another direction is a risk inherent in the game.*** The essence of tort liability is the failure to takereasonable steps, where possible, to minimize the chance ofharm. Thus, to establish liability in tort, there must beboth the existence of a recognizable risk and some basis forconcluding that the harm flowing from the consummation of thatrisk was reasonably preventable.

Since ' "even the best professional golfers cannot avoidan occasional 'hook' or 'slice' " ' [citation], it cannot besaid that the risk of a mishit golf ball is a fullypreventable occurrence. To the contrary, even with the utmostconcentration and 'tedious preparation' that often accompaniesa golfer's shot [citation], there is no guarantee that theball will be lofted onto the correct path. For that reason,we have held that the mere fact that a golf ball did nottravel in the intended direction does not establish a viable negligence claim [citation]. To provide an actionable theoryof liability, a person injured by a mishit golf ball mustaffirmatively show that the golfer failed to exercise due careby adducing proof, for example, that the golfer 'aimed soinaccurately as to unreasonably increase the risk of harm'[citation]." (Emphasis in original.) Rinaldo, 78 N.Y.2d at733, 587 N.E.2d at 267, 579 N.Y.S.2d at 629; see also Benjaminv. Nernberg, 102 Pa. Super. 471, 476, 157 A. 10, 11 (1931)("It is common knowledge, at least among players, that manybad shots must result although every stroke is delivered withthe best possible intention and without any negligencewhatever").

In this case, there is no evidence of anything more than a badshot. Contrary to plaintiff's argument, defendant never admittedthat any particular factors contributed to his tee shot veeringfrom its intended path. Defendant identified a few common errorswith golf swings but had no knowledge whether he made any of thoseerrors.

Plaintiff cites Zurla v. Hydel, 289 Ill. App. 3d 215 (1997),which held that because golf is not a contact sport, a participant who suffers an injury may recover based on simple negligence andneed not allege and prove willful and wanton conduct. Zurla alsoadopted a "zone of danger" analysis requiring a golfer to exerciseordinary care for the safety of persons reasonably within the rangeof danger of being struck by the ball. Zurla, 289 Ill. App. 3d at222, citing D. Holliday, Annotation, Liability to One Struck by aGolf Ball, 53 A.L.R.4th 282, 289 (1987). Plaintiff contends thatthere are issues of fact about the distance between plaintiff anddefendant and the angle between plaintiff and the intended path ofdefendant's shot. According to plaintiff, these issues are germaneto whether plaintiff was within the zone of danger. However,plaintiff's presence in the zone of danger is not enough toestablish liability because, as discussed, plaintiff has not shownthat there is any basis to find that defendant failed to exercisedue care in making his tee shot. Zurla does not impose absoluteliability on a golfer whose ball hits another golfer within thezone of danger. Since the absence of a genuine issue as tonegligence in this case precludes recovery, it is immaterialwhether plaintiff was in the zone of danger. See Westbank v.Maurer, 276 Ill. App. 3d 553, 562 (1995) ("facts which would notaffect the outcome of a party's case, regardless of how sharplythose facts are controverted, will not warrant the denial of amotion for summary judgment").

For the foregoing reasons, the judgment of the circuit courtof Lake County is affirmed.

Affirmed.

BYRNE and KAPALA, JJ., concur.