PGA Tour, Inc. v. Martin
The Supreme Court ruled that a disabled professional golfer, Casey Martin, had a right under the Americans with Disabilities Act to use a golf cart during PGA TOUR competitions, because the tour's walking rule was not essential to the game and waiving it for him would not give him an unfair edge.
The decision confirms that federal disability law reaches professional sports competitions themselves, not just spectator areas, and requires organizers to individually evaluate whether a disabled competitor's requested accommodation would truly change the nature of the game.
How it got here: A federal trial court ruled for Martin after trial; the Ninth Circuit affirmed; the Seventh Circuit reached the opposite result in a similar case, and the Supreme Court granted review to resolve the conflict.
The Case in Depth
What happened
Casey Martin, a talented golfer with a degenerative circulatory disorder that made walking a golf course dangerous and painful, sought permission from the PGA TOUR to use a golf cart during its qualifying tournament and tour events, which otherwise require players to walk. The PGA TOUR refused, insisting that walking was a substantive rule of competition that could not be waived for any individual, and Martin sued under the Americans with Disabilities Act.
The question before the Court
Could a professional golf tour refuse to let a disabled golfer use a cart, when walking the course was one of its competition rules?
The Court's answer
No — the PGA TOUR could not deny Casey Martin the use of a golf cart. The Court ruled that professional golf tournaments and their qualifying rounds are places of public accommodation under the ADA, and that competing golfers, not just spectators, are protected from disability discrimination there. Because walking the course is not an essential rule of golf itself, and other formats already allow carts, waiving the walking requirement for one golfer would not fundamentally change the sport.
The Court also found that granting Martin a cart specifically would not give him any unfair advantage, since the trial court determined he endures more fatigue riding a cart than his competitors do walking. Because the ADA requires individualized evaluation of each disabled person's accommodation request, the PGA TOUR was wrong to apply a blanket refusal, and Martin's request should have been granted.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Sports leagues and other competitive organizations now know they must consider individualized requests for accommodations from disabled athletes rather than treating every rule as untouchable. Golfers, competitors in other sports, and organizers of competitive events all have clearer guidance on when disability accommodations must be granted versus when they would truly change the competition.
What changes now
This is a final merits decision resolving the circuit split between the Ninth and Seventh Circuits in the PGA TOUR's favor of Martin. Martin was permitted to keep using a cart in tour events. The ruling does not require the PGA TOUR to allow carts for other golfers whose disabilities are less severe or who would gain a genuine competitive advantage; such requests would still require individualized evaluation under the same fundamental-alteration standard.
What this does not decide
The Court did not rule that all disabled golfers, or golfers with less serious conditions, are entitled to use carts—only that Martin's specific circumstances, as found by the trial court, meant a cart would not give him any competitive edge. Requests from other athletes must still be individually evaluated under the same fundamental-alteration test.
Concurrences and dissents
Dissent — Justice Scalia
Justice Scalia argued that Title III of the ADA protects only customers of a business, not the professional golfers who compete in it, comparing golfers to baseball players who are not customers of the leagues that employ them. He also argued that courts have no principled way to decide which rules of a game are 'essential,' since all game rules are arbitrary, and that the majority's individualized fundamental-alteration test would invite endless litigation over which competitors deserve rule exceptions.
How the Court got there
The legal reasoning, step by step
- The Court first asked whether Title III of the ADA, which bars disability discrimination at 'places of public accommodation,' covers the competitors in PGA TOUR events and not just the spectators. Because the statute specifically lists golf courses as covered places, and the tour leases and operates such courses to run its tournaments, the Court held golfers competing there are protected individuals, not merely providers of entertainment for others.
- The Court rejected the tour's argument that only paying spectators count as protected 'customers,' reasoning that golfers who pay an entry fee and compete for a chance to advance are themselves a class of people enjoying a privilege the tour offers to the public, separate from the spectator experience.
- Turning to the ADA's reasonable-modification requirement, the Court explained that a modification is unlawful to deny only if it would 'fundamentally alter' the competition, either by changing an essential aspect of the game itself or by giving the requesting individual a competitive edge over others.
- Applying that framework, the Court found that walking is not an essential rule of golf itself, noting that carts are permitted in many amateur and even some professional formats, and that the basic Rules of Golf never prohibit their use.
- The Court then held that allowing Martin specifically to use a cart would not create a competitive advantage, because the trial court had found that Martin, due to his condition, endures greater fatigue riding a cart than his able-bodied competitors do by walking the course.
- Because the walking rule was not essential to golf and waiving it for Martin did not undercut its fatigue-inducing purpose relative to other competitors, the Court concluded that granting his individualized request was exactly what the ADA's reasonable-modification requirement demands.
Doctrinal impact
Cases affected by this decision
Reaffirms Daniel v. Paul (395 U.S. 298)
The Court relied on this case's holding that public accommodation laws cover participants, not just spectators.
Reaffirms Pennsylvania Dept. of Corrections v. Yeskey (524 U.S. 206)
The Court cited this case to support reading disability law's coverage broadly, even in unanticipated situations.