A lot of people take relief from the cart path on the nicest point of complete relief, not the nearest point of complete relief (this is cheating). If you are right-handed, and the ball is in the middle of the cart path, then your nearest point of relief is to the left of the cart path. It's not always the fairway side. Sorry.
So what if there's a penalty area immediately to the left of the cart path? This is the case on #2 at Balboa, and it came up. That's where complete relief comes in. The definition of complete relief includes the ball being in the required area of the course. This means not in a penalty area. So in this scenario, the nearest point of complete relief is to the right (fairway) side of the cart path.
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