51 IDEA 47 (2011)
Taking a Mulligan: Moral Rights and the Art of Golf Course Design

handle is hein.journals/idea51 and id is 49 raw text is: 47

TAKING A MULLIGAN: MORAL RIGHTS
AND THE ART OF GOLF COURSE
DESIGN
RYAN C. STEINMAN*
I believe in reverencing anything in the life of man which has the
testimony of the ages as being unexcelled, whether it be literature,
paintings, poetry, tombs-even a golf hole.
C.B. MACDONALD'
INTRODUCTION
Recent surveys suggest that people from vastly different backgrounds
and diverse cultures share a vision of what is considered a beautiful landscape.
The most common ideal is a view from a high lookout which overlooks open
Ryan C. Steinman is an associate at O'Melveny & Myers LLP's New York office and has
experience in a broad range of practice areas with particular emphasis on intellectual proper-
ty disputes and commercial litigation. Steinman received his J.D. from New York Law
School, M.S. from Boston University, and B.M.A. from University of Michigan. A shorter
version of this article was originally published in Volume 20, Number I of
the Entertainment, Arts and Sports Law Journal (Spring 2009), a publication of the Enter-
tainment, Arts and Sports Law Section of the New York State Bar Association.
GEOFF SHACKELFORD, GROUNDS FOR GOLF: THE HISTORY AND FUNDAMENTALS OF GOLF
COURSE DESIGN xi (2003) [hereinafter SHACKELFORD, GROUNDS FOR GOLF] (quoting C.B.
Macdonald). Golf historians consider Charles Blair Macdonald the Father of American
Golf Course Architecture. GEOFFREY S. CORNISH & RONALD E. WHITTEN, THE ARCHITECTS
OF GOLF: A SURVEY OF GOLF DESIGN FROM ITS BEGINNINGS TO THE PRESENT, WITH AN
ENCYCLOPEDIA LISTING OF GOLF COURSE ARCHITECTS AND THEIR COURSES 330 (1993).
Macdonald is credited with building the first eighteen-hole golf course in the United States,
coining the title golf architect, and is a founder of the United States Golf Association. Id.
at 330; see also GEOFF SHACKELFORD, THE GOLDEN AGE OF GOLF DESIGN 32-42 (Wiley,
John & Sons, Inc. 2005) (1999) [hereinafter SHACKELFORD, GOLDEN AGE OF GOLF DESIGN]
(discussing Macdonald's many accomplishments).
2   John Tierney, Op-Ed., The GolfGene, N.Y. TIMES, Aug. 20, 2005, at A13.

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