Updated June 19, 2026, 10:43 p.m. ET
- Joaquin Niemann received a two-stroke penalty at the U.S. Open for throwing a club.
- The penalty was issued under a new code of conduct introduced by the USGA this year.
- The incident has sparked debate over what constitutes “serious misconduct” in professional golf.
- Niemann admitted to the act of frustration but felt the two-stroke penalty was excessive.
SOUTHAMPTON, N.Y. — It’s been more than sixty years since Justice Potter Stewart offered his famously concise definition of obscenity: “I know it when I see it.” That elastic standard might also be applied to misconduct in golf, an admittedly broad spectrum but one that most people who have played for a living have at some point registered on.
Tiger Woods, for one. He blitzed broadcasts with F-bombs for two decades, and even slipped a tampon to Justin Thomas mid-round as a juvenile joke. And Phil Mickelson, who childishly slapped a moving ball here at Shinnecock Hills in 2018. How about Josele Ballester, who relieved himself in Rae’s Creek during the Masters? Woody Austin once broke a putter over his own head. Davis Love III, who has the mien and fashion sense of an aspiring altar boy, smashed a sprinkler head at Bay Hill in ’99, causing a geyser that flooded a bunker. Heck, even the sainted sportsman Bobby Jones tore up his scorecard and stormed off the Old Course in St. Andrews during the ’21 Open Championship. (Alert readers will note no citation of Sergio Garcia, on the grounds that selecting one of his infantile outbursts would be unfair to the many left behind).
But which of the aforementioned warrants being sanctioned as misconduct?
The question is part philosophical, part procedural, and a hot topic at the 126th U.S. Open after Joaquin Niemann was hit with a two-stroke penalty for throwing a club during his first round on Thursday evening (the strokes were added Friday morning when the round was completed).
“I’m not someone that like to be in that behavior. I’m the first one to judge myself when I don’t behave on the golf course,” Niemann said. “Yeah, that was a misbehave from my part. I felt like a little bit extra penalized with two-shot penalty, but I think it is what it is. I think I’m going to learn from it.”
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No video of the incident has emerged, but reporter Gabby Herzig of The Athletic quoted a volunteer as saying Niemann launched his club far enough to clear two fairways at old U.S. Open venues, but only one at this year’s. The guilty party confessed that his wedge got some air, but lacked an audience.
“I was looking around. There was no people, obviously. No one there,” he said. “I’m not proud of it, but yeah, I mean, sometimes, you know, all the expectation of trying to play well and things doesn’t go your way, you get frustrated, and that was me there.”
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The USGA didn’t need a player code of conduct for the first 124 editions of this championship, but its absence was noted last year when Wyndham Clark bollixed a locker at Oakmont Country Club, leading to a very public scolding, reparations and a mea culpa. So a code was introduced this year. The policy includes this section:
“Serious Misconduct: If a player’s (or their caddie’s) behavior is so far removed from what is expected in the spirit of the game of golf, in accordance with Rule 1.2b, the Chief Referee, in consultation with the Championship Director, may apply a penalty of two strokes or disqualification, taking account of the frequency, impact, intent and severity of the misconduct.”
Vandalizing facilities at a host club would meet any reasonable interpretation of that language, at least for those who don’t think hoodlums deserve pardons and slush funds. But let’s apply the four metrics cited in the policy to the case of Niemann.
Frequency: He has no track record of this being a regular occurrence, nor a reputation for petulance. Impact: It occurred late in the evening when most fans had left and had no discernible effect on the event, save bruising the reputation of the Chilean. Intent: this would appear to be a simple act of pure frustration, not an attempt to send a message to the USGA or cause injury. That leaves Severity, which is awfully subjective.
Codes of conduct are welcome and often necessary in professional sports, even one that prides itself on decorum. But they also raise tricky questions because misconduct is often in the eye of the beholder. A fusillade of profanity might be amusing to me but grossly offensive to a volunteer side hustling from his day job as a preacher. When it comes to club throwing specifically, what rises to the level of “serious misconduct”? Does the violence of the action matter? Is a tomahawk into the sacred turf at Shinnecock Hills more worthy of punishment than a helicopter that merely brushes the grass? Is an angry flip of the putter toward one’s bag after a three-jack on a par with those?
Is distance covered relevant? One can bury a club without it leaving one’s shadow. Is that more tolerable than a full release that departs Shinnecock Hills and lands on National Golf Links? We can probably agree that the gravity of the infraction is greater if it involves contact with a tee marker or an inattentive spectator, but does it matter who witnesses the misconduct and whose sense of propriety is being offended? Should it be a one-stroke penalty be applied if the nearest spectators were boozy bros from Bethpage, but doubled if they were from the local chapter of the Woman’s Christian Temperance Union?
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The most delicate aspect of all when it comes to conduct codes is enforcement. Niemann was punished, but others who tossed clubs here were not. Of course, the fact that other offenders escaped sanctions is no defense. If it was, a drunk driver stopped by cops can argue that he shouldn’t be penalized because a half-dozen others got bladdered with him and drove home unapprehended. Enforcement largely hangs on a credible report and substantiating evidence. There’s some dispute between Team Niemann and the USGA as to the reliability of both in his case, even if there’s also a little dose of whining that he’s been unfairly singled out.
Given his admission, the offense isn’t in dispute, merely its seriousness and the severity of the response. But the current language of the code of conduct means it falls to the USGA to determine an appropriate punishment, regardless of whether Niemann thinks it too harsh. Maybe it was, but it is what it is. The policy is worded for breadth not specificity so as to cover all potential infractions, but it wouldn’t hurt to have it supplemented with a procedure to resolve incidents that are either disputed or that have sparse evidence.
As Judge Potter Stewart also quipped, swift justice demands more than just swiftness.
Eamon Lynch is a columnist for Golfweek and a frequent contributor to the Golf Channel.