PGA Tour, Inc. v. Martin
149 L. Ed. 2d 904, 2001 U.S. LEXIS 4115, 532 U.S. 661 (2001)
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Rule of Law:
Title III of the Americans with Disabilities Act (ADA) requires owners and operators of public accommodations, including professional sports tours, to make reasonable modifications to their policies for qualified individuals with disabilities, unless the modification would fundamentally alter the nature of the goods, services, or privileges offered. An individualized inquiry is required to determine if a modification is necessary and would not fundamentally alter the nature of the competition.
Facts:
- PGA TOUR, Inc. is a non-profit organization that sponsors professional golf tournaments, including the PGA TOUR and NIKE TOUR.
- PGA TOUR's rules for these elite tournaments require competitors to walk the course during play.
- Casey Martin is a professional golfer afflicted with Klippel-Trenaunay-Weber Syndrome, a degenerative circulatory disorder that causes severe pain and atrophy in his right leg and makes him unable to walk an 18-hole golf course.
- Martin's disability creates a significant risk of hemorrhaging, blood clots, and fracturing his tibia if he walks the course.
- After successfully competing in the first two stages of the PGA TOUR's qualifying school (Q-School) where carts were permitted, Martin requested to use a cart in the third and final stage.
- PGA TOUR denied Martin's request for an accommodation, citing its walking rule, which it considered integral to the competition.
- The official Rules of Golf, which govern the game worldwide, do not prohibit the use of carts; the walking rule is an optional condition that PGA TOUR chooses to enforce.
- PGA TOUR permits the use of carts in its SENIOR PGA TOUR events and in open qualifying rounds for its main tours.
Procedural Posture:
- Casey Martin sued PGA TOUR, Inc. in the U.S. District Court for the District of Oregon, alleging a violation of the Americans with Disabilities Act.
- The District Court granted a preliminary injunction, allowing Martin to use a golf cart during the qualifying school and subsequent tournaments.
- Following a bench trial, the District Court entered a permanent injunction in favor of Martin, holding that the PGA TOUR is a public accommodation and that allowing Martin to use a cart would not fundamentally alter the nature of its competitions.
- PGA TOUR, Inc., as appellant, appealed to the U.S. Court of Appeals for the Ninth Circuit.
- The Ninth Circuit affirmed the trial court's decision, agreeing that the competitions were public accommodations and that waiving the walking rule for Martin was a required reasonable modification.
- The U.S. Supreme Court granted certiorari to resolve a conflict between the Ninth Circuit's decision and a contrary ruling from the Seventh Circuit in a similar case.
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Issue:
Does Title III of the Americans with Disabilities Act require a professional golf tour to grant a waiver of its walking rule to a qualified professional golfer with a disability who cannot walk the course, or would such a waiver 'fundamentally alter the nature' of the competition?
Opinions:
Majority - Justice Stevens
Yes. Title III of the ADA requires the PGA TOUR to grant Martin a waiver of its walking rule because using a golf cart is a reasonable modification necessary to accommodate his disability and does not fundamentally alter the nature of the competition. First, Title III applies to the PGA TOUR's competitions because the golf courses are places of public accommodation, and the opportunity to compete is a 'privilege' that the PGA TOUR offers to the public, making competitors like Martin protected individuals under the Act. Second, allowing Martin to use a cart is a required 'reasonable modification' because it does not 'fundamentally alter' the nature of the tournaments. The Court reasoned that the essence of golf is shot-making, not walking, and the walking rule is not a core component of the game itself. Based on an individualized inquiry, the Court accepted the District Court's finding that Martin, even with a cart, endures greater fatigue from his disability than able-bodied competitors do from walking. Therefore, waiving the rule for Martin does not compromise the rule's purpose of injecting fatigue into the competition and grants him meaningful access, which is the core purpose of the ADA.
Dissenting - Justice Scalia
No. Title III of the ADA is intended to protect clients and customers of a public accommodation, not the performers or independent contractors who provide the entertainment. Martin is a professional athlete selling his performance, not a customer enjoying a service, and thus is not covered by Title III. Even if he were covered, the ADA does not regulate the content of the services offered; it only guarantees access to them. The PGA TOUR offers the 'product' of walk-around golf, and it is not required to create a different product—ride-around golf—for a disabled competitor. Furthermore, it is not the role of a court to determine which rules of a sport are 'essential.' A game is defined by its arbitrary rules, and for the PGA TOUR to change any rule is to fundamentally alter the competition it has created. The majority's individualized approach to athletic capacity guarantees future litigation and wrongly transforms the ADA's guarantee of equal access into a guarantee of an equal chance to win.
Analysis:
The PGA TOUR v. Martin decision significantly expanded the application of Title III of the ADA, extending its protections beyond traditional 'customers' to participants in high-level professional athletic competitions. The ruling established that sports governing bodies do not have absolute autonomy over their rules and that courts can scrutinize those rules to determine if they are 'essential' to the sport or merely 'peripheral' when a disabled athlete requests an accommodation. This precedent requires an individualized, fact-based inquiry into the nature of both the sport's rules and the athlete's disability, shifting the burden to sports organizations to justify rules that have a discriminatory effect. The decision has had a lasting impact on how sports leagues and associations must balance the integrity of their competitions with the civil rights of athletes with disabilities.
