Mulligan hailed from Ontario, Canada. He owned a string of hotels in the northeast, including a piece of New York City’s Biltmore Hotel. He loved golf. One day in the 1920s, Mulligan hit a wayward tee shot on the first hole. To the surprise of the three other players in his foursome, Mulligan instinctively reached down, teed another ball, and hit a second drive. His playing partners questioned his tactic.

“I’m taking a correction shot,” Mulligan explained. He called it a “mulligan.” The justification for and acceptance of his action is disputed. Some say he did it because he arrived late and didn’t have time to properly warm up. Others contend a rough and bumpy ride to the course left him nervous and with shaky hands, and his opponents took pity.