PGA Tour Inc., v Martin (2001)

Facts: Casey Martin is a very talented golfer. He won 17 amateur events before the age of 15, and won the state championship in Oregon as a high school senior. As a professional, Mr. Martin qualified for the Nike Tour of 1998 and 1999, and qualified for the PGA Tour in 2000. He is also an individual with a disability as defined under the Americans with Disabilities Act of 1990 (ADA). Since birth he has been afflicted with Klippel-Trenaunay-Weber Syndrome (Parkes-Weber syndrome), which is a degenerative circulatory disorder that obstructs the flow of blood from his right leg back to his heart. The disease is progressive and causes severe pain and has atrophied his right leg. During the latter part of his collegiate career, the Pac 10 Conference and NCAA waived their rules for Mr. Martin requiring players to walk and carry their own golf clubs. The basic rules of the PGA Tour Inc. and to all players in tour competitions is that everyone would tee off on the first hole under exactly the same conditions (namely, the Masters Tournament which is golf at its highest level), and that each person would perform under the same conditions that exist over the four days of the 72-hole event. The PGA interpretation of the rules was that Mr. Martin’s use of a cart for participation in the Masters Tournament would be an unfair advantage, so they would not allow him to use a cart. Mr. Martin filed a discrimination suit against the PGA Tour claiming violations of the Americans with Disabilities Act.

Decisions Below: The lower court and court of appeals both found that denying Martin the use of a cart violated the ADA and required the PGA to permit Martin to use a cart pursuant to the act’s rules on reasonable accommodation. The PGA appealed.

Legal Issue(s): Whether or not the PGA violated the Americans with Disabilities Act by denying Martin the use of a cart in the PGA Tour in conjunction with and due to the necessity of his disability.

Holding: Yes. Affirmed
Reasoning: The courts ultimately concluded that walking is not a “fundamental” aspect of golf. They felt that Martin was still a qualified and accomplished golfer despite his disability and special needs/accommodations. Under the