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Keywords

lawsuitplaintiffinjunctionmotiondiscrimination
plaintifflitigationinjunctionmotion

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Barron v. PGA Tour, Inc., 670 F.Supp.2d 674

Facts

Doug Barron, a professional golfer diagnosed with mitral valve prolapse, received a one-year suspension from the PGA Tour for using prohibited substances, including exogenous Testosterone and Propranolol. He filed a lawsuit against the PGA Tour, claiming violations of the Americans with Disabilities Act (ADA) and other state law claims, seeking a temporary restraining order (TRO) to allow him to compete in a qualifying tournament. The case was removed to federal court after being initially filed in state court.

Doug Barron is a professional golfer who joined the PGA Tour in January of 1995. In 1987, when he was eighteen years old, he was diagnosed with mitral valve prolapse and was prescribed a beta blocker, Propranolol, to treat the condition. Without Propranolol, Barron experiences a racing heartbeat and chest pains.

Issue

Did Barron demonstrate a likelihood of success on the merits of his ADA claim and other state law claims to warrant the issuance of a temporary restraining order?

Did Barron demonstrate a likelihood of success on the merits of his ADA claim and other state law claims to warrant the issuance of a temporary restraining order?

Rule

To issue a temporary restraining order, the court applies a four-factor test: (1) likelihood of success on the merits, (2) irreparable harm if the injunction is not granted, (3) substantial harm to others if the injunction is granted, and (4) whether the public interest would be served by the injunction. The plaintiff must show more than a mere possibility of success; serious questions must be raised regarding the merits.

Temporary restraining orders and preliminary injunctions are extraordinary remedies which should be granted only if the movant carries his burden of proving that the circumstances clearly demand it.

Analysis

Barron argued that he was disabled under the ADA due to his low Testosterone levels, which he claimed limited his ability to engage in major life activities. However, the court found that while he showed a strong likelihood of success regarding his claim of being disabled, he did not demonstrate that the PGA Tour's actions constituted discrimination under Title III of the ADA. The court noted that the PGA Tour's denial of his Therapeutic Use Exemption (TUE) applications was not arbitrary or capricious, and thus did not warrant a TRO.

In order to establish 'likelihood of success' on merits of claim, plaintiff must show more than mere possibility of success; however, it is ordinarily sufficient if plaintiff has raised questions going to merits so serious, substantial, difficult, and doubtful as to make them fair grounds for litigation and thus for more deliberative investigation.

Conclusion

The court denied Barron's motion for a temporary restraining order, concluding that he did not show a likelihood of success on the merits of his ADA claim.

The court, having now considered the arguments of counsel and the entire record in this case, denies the motion for a temporary restraining order.

Who won?

The PGA Tour prevailed in this case as the court denied Barron's request for a temporary restraining order. The court found that Barron did not demonstrate a strong likelihood of success on the merits of his ADA claim, particularly regarding the PGA Tour's actions in denying his TUE applications. The court emphasized that the PGA Tour's decisions were not arbitrary and that Barron had not sufficiently established that he was denied public accommodations due to his disability.

The PGA Tour prevailed in this case as the court denied Barron's request for a temporary restraining order.

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