PGA Tour, Inc. v. Martin (2001)
- Sam Shepherd
- Sep 23, 2024
- 3 min read
Updated: Oct 27, 2024
By Nityanshi Rao
Overview
PGA Tour, Inc. v. Martin (2001) was a landmark Supreme Court case addressing whether the Americans with Disabilities Act (ADA) required the PGA Tour to accommodate a golfer with a disability by allowing him to use a golf cart during professional tournaments. The Court ruled 7-2 in favor of Casey Martin, who had a degenerative circulatory disorder, determining that this accommodation was reasonable under the ADA and did not fundamentally alter the nature of the sport.
Summary
The case revolved around Casey Martin, a professional golfer with a circulatory condition that made walking golf courses extremely painful and difficult. Martin’s disability, which was recognized under the ADA, significantly affected his ability to compete without a cart. The PGA Tour denied Martin’s request to use a golf cart, citing their walking rule as essential to maintaining the integrity of professional golf, particularly emphasizing that walking introduced an element of physical endurance integral to the game.
Martin sued the PGA Tour under Title III of the ADA, which requires public accommodations to make reasonable modifications to avoid discrimination against individuals with disabilities. A district court initially ruled in Martin’s favor, finding that the PGA Tour was indeed a public accommodation and that the walking rule’s purpose of adding fatigue to competition was not fundamentally compromised by allowing Martin to use a cart, as his condition already caused significant fatigue even when riding. The court of appeals upheld this decision, asserting that professional golf tournaments fall under the ADA’s provisions for public accommodations.
The Supreme Court agreed in a 7-2 decision, with Justice John Paul Stevens writing the majority opinion. The Court concluded that the ADA applied to professional golf tournaments, as they occur in places of public accommodation, and that allowing Martin to use a cart did not fundamentally alter the nature of the game. The majority rejected the PGA Tour’s argument that the walking rule was essential to the sport’s integrity, emphasizing that the rule’s primary purpose—to induce fatigue—was already satisfied due to Martin’s disability. Justice Antonin Scalia dissented, arguing that the decision distorted the rules of the game, comparing the ruling to Kurt Vonnegut’s dystopian story "Harrison Bergeron," where everyone is forced to compete on the same level by handicapping the able-bodied.
Impact
This ruling was a significant milestone in the application of the ADA, particularly in the context of professional sports. The case set a precedent that sports organizations must comply with ADA regulations and provide reasonable accommodations to athletes with disabilities, as long as the modifications do not fundamentally alter the nature of the sport.
The decision highlighted the balance between maintaining the integrity of competition and ensuring fair access for disabled individuals. It reinforced that professional sports, while often associated with tradition and strict rules, must adapt to the principles of inclusion and equality embedded in the ADA. The ruling has since been cited in other cases involving the ADA and reasonable accommodations, extending beyond sports to various public domains, further strengthening disability rights in the U.S.
However, the case also sparked debates about the limits of ADA applicability in professional sports, with some arguing that this ruling could open the door to further alterations of traditional sports rules in the name of accommodation. Despite this, the ruling remained specific to Martin’s unique circumstances and did not lead to widespread changes in professional golf’s walking rules.
Sources
To read the full Supreme Court Opinions and Dissents, click here:
PGA Tour, Inc. v. Martin, 532 U.S. 661 (2001)
To read the U.S. Court of Appeals for the Ninth Circuit's opinion, click here:
Martin v. PGA Tour, Inc., 204 F.3d 994 (9th Cir. 2000)
Citations
PGA Tour, Inc. v. Martin, 532 U.S. 661 (2001)
Americans with Disabilities Act of 1990, 42 U.S.C. § 12101 et seq.
"Casey Martin and the Supreme Court: A Retrospective," Journal of Sports Law
"The ADA's Application in Professional Sports: An Analysis of PGA Tour, Inc. v. Martin," Columbia Law Review
