Summary of PGA Tour, Inc. v. Casey Martin
The Supreme Court's Review of the PGA's ADA Obligations
Barry C. Taylor Legal Advocacy Director, Equip for Equality, Inc.
The Facts of the Martin Case
Casey Martin is a professional golfer who has a congenital, degenerative circulatory disorder. This condition causes Martin severe pain and atrophy in his lower leg, rendering him unable to walk for extended periods of time. The Professional Golf Association ("PGA") has a requirement that players walk the course during tournaments, a requirement that Martin cannot meet. Martin requested that the PGA make a reasonable modification of its "walking rule" and allow him to use a golf cart during tournaments. The PGA refused and Martin filed suit under Title III of the ADA.
The PGA did not dispute that Martin has a disability under the ADA. Instead, it claimed that it was not required to grant Martin's request because the playing area of a golf course used during professional tournaments is not a place of public accommodation under the ADA. The PGA also argued that allowing Martin to use a golf cart would fundamentally alter the competition and therefore, the PGA should not have to modify its walking rule. The trial court and the 9th Circuit Court of Appeals found in favor of Martin, and the U.S. Supreme Court agreed to review the case.
The Supreme Court's Decision
On May 29, 2001, the Supreme Court, by a vote of 7-2, ruled that Martin may use a golf cart to compete in PGA tournaments, and that to deny Martin's request was a violation of the ADA. The Court addressed two separate issues:
First, it considered whether a golf course used for a PGA Tour event was a place of public accommodation. The Court found that, given the comprehensive statutory definition of "public accommodation," golf tours and their qualifying rounds fit well within Title III's scope, and that golf courses are places of public accommodation.
Second, the Court considered whether allowing Martin to use a golf cart would fundamentally alter the game such that the PGA would not have to modify its walking rule. The Court held that allowing Martin to use a golf cart would not constitute a fundamental alteration. Specifically, the Court found that allowing Martin to use a cart would not change a fundamental aspect of the game, because walking is not an essential aspect of the game of golf. The Court further found that allowing Martin to use a cart would not give him an unfair advantage because Martin endures far more fatigue even when using a cart than do the other PGA competitors.
Potential Implications of the Supreme Court's Ruling in Martin
- Failure to provide reasonable modifications is discrimination under the ADA. The Supreme Court confirms that public accommodation discrimination is not limited to outright intentional exclusion, but includes the "failure to make modifications to existing facilities and practices."
- The Supreme Court embraces liberal construction of the term public accommodation. The Supreme Court expressly states that the term public accommodation "should be construed liberally to afford people with disabilities equal access to the wide variety of establishments available to the non-disabled." This may prove helpful to people with disabilities when entities claim the ADA does not apply to them, such as insurance companies.
- The Supreme Court states that the ADA can apply in situations not originally contemplated by Congress. As part of its finding that the playing areas of golf courses during professional tournaments are places of public accommodation, the Court states that "the fact that a statute can be applied in situations not expressly anticipated by Congress does not demonstrate ambiguity. It demonstrates breadth." This may be helpful to people with disabilities to get courts to expand the application of a variety of terms in the ADA, including "places of public accommodation" and "major life activities."
- The Supreme Court relies upon the ADA's legislative history. In its decision, the Supreme Court states that one of the ADA's greatest strengths is its "comprehensive character." In support of this statement, the Court quotes from Senate hearings on the ADA. Reliance upon testimony from the Senate hearings demonstrates the Court's deference to the legislative history of the ADA in making its decision. This deference to legislative history may be useful to people with disabilities in future cases in which the statute is not clear on its face, but the legislative history is helpful.
- The Supreme Court emphasizes the importance that ADA-covered entities conduct individualized assessments. In its opinion, the Supreme Court states that the PGA failed to conduct an individualized assessment in response to Martin's request as required by the ADA, and instead improperly applied its walking rule without taking into consideration the particular circumstances of Martin. The Court's insistence that entities covered by the ADA conduct individualized assessments will be helpful to people with disabilities who are experiencing difficulties because of a broad exclusionary rule or policy. In addition to cases of reasonable modification (Titles II and III) and reasonable accommodation (Title I), the Court's opinion may be useful when a person with a disability is deemed a direct threat without an individualized assessment as to whether the person is indeed a threat to others. The Court's opinion also rejects that administrative burden can be a basis for a public accommodation to fail to meet its obligation to conduct an individualized assessment.
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