PGA Tour, Inc. v. Martin
Headline: Court applies the Americans with Disabilities Act to professional golf, upholds a disabled golfer’s right to use a cart, and requires tournaments to consider individualized accommodations instead of blanket walking rules.
Holding: The Court decided that Title III of the ADA covers PGA Tour competitions and that denying Casey Martin a golf cart violated the Act because an individualized accommodation would not fundamentally alter the tournaments.
- Requires sports organizers to consider individualized disability accommodations.
- Gives disabled golfers access to tournaments by permitting carts when necessary.
- May increase administrative reviews and litigation over accommodation requests.
Summary
Background
The case involves PGA TOUR, a nonprofit that runs professional golf tours and the qualifying "Q-School," and Casey Martin, a talented professional golfer born with Klippel-Trenaunay-Weber syndrome who cannot safely walk an 18-hole course. Martin asked to use a golf cart in the final stage of qualifying and in tournaments after PGA TOUR enforced a walking rule and refused to review his medical records. A district court issued an injunction allowing the cart; the Ninth Circuit affirmed, and a different court reached the opposite result in a related case, so the Supreme Court agreed to decide the questions.
Reasoning
The Court addressed whether Title III of the ADA covers tour competitions and whether a cart would "fundamentally alter" those events. The majority held that tour events are places of public accommodation and that competitors can be customers entitled to individualized accommodation decisions. The Court found that a golf cart was a reasonable and necessary modification for Martin and that allowing him to ride would not fundamentally change the nature or purpose of PGA and NIKE Tour competitions given the walking rule’s peripheral role and the trial findings about Martin’s greater fatigue.
Real world impact
The ruling requires organizers of elite sports held at public facilities to evaluate accommodation requests case by case and consider reasonable modifications when necessary. Golf tours must weigh individual medical evidence before refusing accommodations, and organizations may face more administrative reviews and some litigation. The decision leaves open future disputes about other rules.
Dissents or concurrances
Justice Scalia dissented, arguing Title III protects customers not independent contractors like professional athletes, and warning against judicial second-guessing of essential sports rules.
Opinions in this case:
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