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Casey IRACs are produced by an AI that analyzes the opinion’s content to construct its analysis. While we strive for accuracy, the output may not be flawless. For a complete and precise understanding, please refer to the linked opinions above.

Keywords

injunctiondiscrimination

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PGA Tour, Inc. v. Martin, 532 U.S. 661, 121 S.Ct. 1879, 149 L.Ed.2d 904, 11 A.D. Cases 1281, 20 NDLR P 188, 01 Cal. Daily Op. Serv. 4294, 2001 Daily Journal D.A.R. 5217, 14 Fla. L. Weekly Fed. S 271, 2001 DJCAR 2634

Facts

Professional golfer Casey Martin, who suffers from a circulatory disorder that affects his ability to walk, sued the PGA Tour, a non-profit professional golf association, after they denied his request to use a golf cart during tournaments. Martin argued that the association's rule prohibiting golf carts violated the Americans with Disabilities Act (ADA). The District Court ruled in favor of Martin, granting a permanent injunction that required the PGA Tour to allow him to use a cart. The case was subsequently affirmed by the Ninth Circuit and reached the Supreme Court.

Issue

Does the Americans with Disabilities Act (ADA) require a professional golf association to allow a disabled golfer to use a golf cart during tournaments, despite a rule requiring players to walk?

Whether the Americans with Disabilities Act (ADA) protects access to professional golf tournaments by a qualified entrant with a disability.

Rule

Title III of the ADA prohibits discrimination against individuals with disabilities in places of public accommodation, requiring reasonable modifications to policies when necessary to afford individuals with disabilities equal access, unless such modifications would fundamentally alter the nature of the goods, services, facilities, privileges, advantages, or accommodations provided.

Analysis

The court analyzed whether allowing Martin to use a golf cart would fundamentally alter the nature of the PGA Tour's competitions. It concluded that the use of a cart does not change the essential character of the game of golf, which is primarily about shot-making. The court found that the walking requirement was not an indispensable feature of tournament golf and that Martin's use of a cart would not provide him with a competitive advantage over able-bodied players, as he experiences greater fatigue even with the cart.

Conclusion

The Supreme Court held that the PGA Tour must allow Casey Martin to use a golf cart during tournaments, affirming that such accommodation is required under the ADA and does not fundamentally alter the nature of the competitions.

The Court concluded that it would 'not fundamentally alter the nature of the PGA Tour's game to accommodate him with a cart.'

Who won?

Casey Martin prevailed in this case as the Supreme Court ruled in his favor, affirming the lower courts' decisions that the PGA Tour's walking requirement constituted discrimination under the ADA. The Court emphasized that the ADA mandates reasonable accommodations for individuals with disabilities, and that allowing Martin to use a golf cart was a necessary modification to ensure his equal access to the tournaments.

The judge concluded that it would 'not fundamentally alter the nature of the PGA Tour's game to accommodate him with a cart.'

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