The Historical Significance of the U.S. Supreme Court’s 2001 decision in PGA Tour, Inc. v. Martin

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On January 17, 2001, the U.S. Supreme Court heard arguments for PGA Tour, Inc. v. Martin. Historically, the court has often strayed from sports-related disputes, although there are some landmark cases which were exceptions and shaped the national landscape of sports. However, the dispute in Martin spanned greatly beyond a mere sports-related dispute. The issue was simple: does using a golf cart fundamentally alter a tournament? However, the larger legal question was whether the American Disabilities Act of 1990 (ADA) supersedes the rules of the PGA Tour.

The ADA is a civil rights law that prohibits discrimination based on disabilities. Among other protections, the ADA requires covered employers to provide reasonable accommodations to employees with disabilities. In this case, former professional golfer, Casey Martin, suffered from a circulatory disorder that prevented him from walking golf courses. His circulatory disorder was a covered disability under the ADA.

However, PGA Tour, Inc. had a strict rule that golfers could not use golf carts under any circumstances. Their view was that the fatigue of walking the course was a significant portion of the competitive element of their professional golfing events. The late Justice John Paul Stevens, who wrote the majority opinion, recognized in the Martin decision that the rule’s purpose was “. . . to inject the element of fatigue into the skill of shot-making . . .” into the sport. However, he argued that “. . . allowing Martin to use a golf cart would not fundamentally alter the nature of . . .” PGA Tour golf events.

As an operator of golf courses, the court ruled that PGA Tour, Inc. must adhere to the ADA and must not discriminate against any “individual” in the “full and equal enjoyment of the goods, services, facilities, privileges, advantages, or accommodations” of their courses. What made this decision complicated was that PGA golfers are not direct employees of PGA Tour, Inc., but rather fall under the category of a “client or customer” under Title III of the ADA, because golfers often pay fees to qualify for certain PGA events on its courses.

Justice Stevens and the other majority justices rejected the PGA Tour’s argument that using a golf cart at the highest level of its competitions fundamentally altered the nature of its events. Furthermore, the protections under the ADA were ruled to extend to Martin. He was allowed to use a golf cart during PGA competition. The court ruled in favor of Martin in a 7-2 decision. Justice Scalia argued, among other contentions, that Martin was not a customer but rather a professional golfer selling the tournaments. He felt that the PGA was not obligated to provide Martin with a different “game” than other golfers are offered.

The ruling in Martin was a major win for disabled athletes in the sports realm. Although significantly disabled athletes often have their own leagues and tournaments in various sports, many disabled athletes, particularly in golf, can still participate in the actual game of golf itself at the same capacity as other non-disabled golfers. This paved the way for the potential of injured war veterans and other disabled golfers to still chase their dreams of becoming professional golfers.

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