How has the doctrine of liability been interpreted in the context of personal injury claims in waterskiing?

generally have reasoned that vigorous participation in the sport likely would be chilled, and, as a result, the nature of the sport likely would be altered, in the event legal liability were to be imposed on a sports participant for ordinary careless conduct. [Citation.] This reasoning applies to waterskiing. Even when a water-skier is not involved in a 'competitive' event, the skier has undertaken vigorous, athletic activity, and the ski boat driver operates the boat in a manner that is consistent with, and enhances, the excitement and challenge of the active conduct of the sport. Imposition of legal liability on a ski boat driver for ordinary negligence in making too sharp a turn, for example, or in pulling the skier too rapidly or too slowly, likely would have the same kind of undesirable chilling effect on the driver's conduct that the courts in other cases feared would inhibit ordinary conduct in various sports. As a result, holding ski boat drivers liable for their ordinary negligence might well have a generally deleterious effect on the nature of the sport of waterskiing as a whole." (Ibid.; see also Shin v. Ahn (2007) 42 Cal.4th 482, 497 [doctrine applied to claim of golfer injured by errant tee shot of partner; partner as coparticipant only liable for intentional misconduct or reckless conduct outside the range of ordinary activity involved in sport]; Cheong, supra, 16 Cal.4th at p. 1068 [claim of snow-skier injured by friend and fellow skier after collision on slopes was barred under doctrine because defendant, as coparticipant in active sport, was liable only for intentionally or recklessly caused injuries].)⁹