PGA Tour, Inc. v. Martin, 532 U.S. 661 (2001) 1

PGA Tour, Inc. v. Martin, 532 U.S. 661 (2001) Case Brief

Elizabeth Valade

Southern New Hampshire University

Sport Law

SPT-610

Dr. Brent Estes

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PGA TOUR, INC. V. MARTIN, 532 U.S. 661 (2001) 2

PGA TOUR, INC. V. MARTIN, 532 U.S. 661 (2001) CASE BRIEF

Facts Casey Martin (“plaintiff”) was born with a birth defect of circulatory condition in his

lower right leg that prevented him from walking golf courses to compete. His disorder constitutes a disability under the Americans with Disabilities Act of 1990 (ADA, n.d.). The rules in the PGA Tour (“defendant”) do not allow for the use of a cart during tour events. In 1997, while attempting to qualify for the PGA Tour through the Q-course, Mr. Martin petitioned the PGA to allow him to use a cart during the third and final stage. The PGA Tour denied his request stating that his use of the cart would fundamentally alter the game. Mr. Martin filed a suit against the PGA Tour based on discrimination.

In November 1997, Mr. Martin filed a lawsuit with the U.S. District Court in Oregon. During the hearing the PGA Tour argued that the District Court did not have jurisdiction over the Tour (which is headquartered in Florida), and that the Tour was a private organization to which the ADA did not apply. The U.S. District Court granted a temporary injunction to Mr. Martin allowing him to use a cart until a trial could occur in February 1998. In February 1998, the court ruled that the ADA required the PGA Tour to allow Martin to ride a cart during competition. The PGA Tour appealed, and the case was referred to the Ninth Circuit. In May 1999, the Ninth Circuit began hearing the case and in March 2000, the Ninth Circuit released its opinion affirming the decision of the District Court and Martin’s right to a cart under the ADA. The PGA Tour brought its appeal to the United States Supreme Court.

Issues Did the PGA Tour discriminate against Martin by not allowing him to use a golf cart to

compete in PGA Tour events? Does the PGA Tour compete on a public accommodation which would require the

organization to follow the Title III of the ADA?

Holding On January 17, 2001, the Supreme Court heard oral arguments in the case of PGA Tour v

Martin. On May 29, 2001the United States Supreme Court handed down a 7-2 decision in favor of Martin. The Court affirmed the Ninth Circuit opinion and held that Title III prohibited the Tour from denying Martin use of a cart on its tours.

Rationale As a rule, Title III prohibits discrimination based on disability in the full and equal

enjoyment of “goods, services, facilities, privileges, [or] advantages” of any public accommodation by any person who “owns, leases (or leases to), or operates a public accommodation (42 U.S. code § 12182 – Prohibition of discrimination by public accommodations, n.d.). Golf Courses are listed as one of the twelve extensive categories. The court found that golf tours and qualifying rounds are public accommodations covered by the ADA as the PGA Tour offered people to either be spectator or competitors. By paying for his entry, Mr. Martin was a customer. The US Supreme Court ruled that lower the use of a cart was a reasonable accommodation and not a fundamental alteration of the game.

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PGA TOUR, INC. V. MARTIN, 532 U.S. 661 (2001) 3

Discussion In the case Pryor V. NCAA (2002), the court ruled in favor of the NCAA. The Third

Circuit Court of Appeals determined that the NCAA did not violate the ADA. Pryor was diagnosed with a learning disability. Under the NCAA rules, a student that has a learning disability will be granted an additional year of eligibility if they complete 75% of their degree requirements at the completion of their fourth year in college. At the time of the lawsuit, Pryor had not entered her fourth year at San Jose State, and she had the ability to regain her eligibility based up the NCAA rules governing student athletes with disabilities.

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PGA TOUR, INC. V. MARTIN, 532 U.S. 661 (2001) 4

References

Cotten, D. J., & Wolohan, J. T. (2017). Law for Recreation & Sport Managers (8th ed). Dubuque, IA:

Kendall Hunt.

PGA Tour, Inc. v. Martin, 532 U.S. 661 (2001) https://heinonline-

org.ezproxy.snhu.edu/HOL/CaseLawAuth?

cid=4470833&native_id=4470833&rest=1&collection=fastcasefull

Pryor V. NCAA, 288 F.3d 548 (3d Cir. 2002) https://caselaw.findlaw.com/us-3rd-

circuit/1302741.html

42 U.S. code § 12182 – Prohibition of discrimination by public accommodations. (n.d.). LII / Legal

Information Institute. https://www.law.cornell.edu/uscode/text/42/12182

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