PGA Tour Inc V Martin 532 US 661 2001 610077

Pga Tour Inc V Martin 532 Us 661 2001 1pga Tour Inc V Marti

Pga Tour Inc V Martin 532 Us 661 2001 1pga Tour Inc V Marti

PGA Tour, Inc. v. Martin, 532 U.S. FactsCasey 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). 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?

HoldingOn January 17, 2001, the Supreme Court heard oral arguments in the case of PGA Tour v Martin. On May 29, 2001, the 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.

RationaleAs 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). 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 spectators or competitors. By paying for his entry, Mr. Martin was a customer. The US Supreme Court ruled that the lower use of a cart was a reasonable accommodation and not a fundamental alteration of the game.

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 NCAA rules, a student with a learning disability can be granted an additional year of eligibility if they complete 75% of their degree requirements at the end of their fourth year in college. At that time, Pryor had not yet entered her fourth year at San Jose State, and she could regain her eligibility based on NCAA rules governing student athletes with disabilities.

References

  • Cotten, D. J., & Wolohan, J. T. (2017). Law for Recreation & Sport Managers (8th ed.). Kendall Hunt.
  • PGA Tour, Inc. v. Martin, 532 U.S. (2001). https://org.ezproxy.snhu.edu/HOL/CaseLawAuth?cid=&native_id=&rest=1&collection=fastcasefull
  • Pryor v. NCAA, 288 F.3d 548 (3d Cir. 2002). https://circuit.html
  • 42 U.S. code § 12182 - Prohibition of discrimination by public accommodations. (n.d.). Legal Information Institute. https://www.law.cornell.edu/uscode/text/42/12182
  • American with Disabilities Act of 1990, 42 U.S.C. §§ 12101 et seq.
  • Gordon, A. (2003). Disability Discrimination in Sports. Journal of Sports Law & Licensing, 10(2), 210-234.
  • Grimm, N. (2015). Accessibility and Equity in Sports Law. Sports Management Review, 18(3), 347-360.
  • Henschen, M. (2019). The Impact of ADA Regulations on Sporting Events. International Journal of Sport Policy and Politics, 11(4), 543-560.
  • Shapiro, M. (2014). Legal Aspects of Sports. Routledge.
  • Williams, S. (2020). Disability Rights and Sports: A Review of Landmark Cases. Sports Law Journal, 28(1), 45-67.

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