The Chautauqua Bird, Tree and Garden Club, founded in 1913 as a private volunteer organization of summer residents at the historic Chautauqua Institution in western New York, has no liability to a guest who was injured when a tree fell on her on Institute property. A federal District Court in New York has granted summary judgment to the Garden Club dismissing the claims. The Garden Club was incorporated as a nonprofit corporation in 2002. Its purpose is to preserve, protect and promote the flora, fauna and culture of the Chautauqua area, to provide educational programs and “to improve society by fostering better awareness and appreciation of the co-existence of human communities and the...