PGA Tour, Inc v Martin - Case Summary

University / Undergraduate
Modified: 22nd Feb 2024
Wordcount: 561 words


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Legal Case Summary

Summary: US Supreme Court case determining whether the American Disabilities Act applies to professional golf tours.


The defendant, Casey Martin, was a professional golfer diagnosed with a circulatory disorder that impeded his ability to walk long distances. Because of this, Martin sought permission to use a golf cart on the PGA tour (an exception to the walking rule) to accommodate his disability. The PGA Tour refused and argued that the walking rule was a fundamental aspect of the competition, denying Martin's ADA claim.

Martin sued under the ADA, and both the District Court and the Ninth Circuit Court of Appeals ruled in his favour. The PGA appealed to the US Supreme Court.


The primary issue was whether the ADA applied to professional sports and whether personal use of a golf cart by Martin could fundamentally alter the nature of the game, thereby providing the PGA Tour with a legitimate reason to deny his request. Furthermore, the case scrutinized whether PGA Tour, a commercial company, was subject to ADA as Martin was considered a 'public' rather than 'private' individual.


The case was a landmark decision determining how the ADA applies to professional sports. It expanded the interpretation of 'public accommodations' to include commercial entities like the PGA Tour. Crucially, it examined the nature of the 'essential rules' of sports competitions and limits on how these rules can be modified to accommodate players with disabilities.


The Supreme Court ruled in favour of Martin, concluding that the ADA did apply to the PGA Tour as a 'public accommodation'. The Court held that allowing a competitor a golf cart would not fundamentally alter the nature of the tournament. Justice Stevens wrote that the central competition in golf is shot-making.

The Court further stated that the PGA Tour could not meet its burden of showing that walking is so significant to golf that changing it for Martin would fundamentally alter its nature.



  • PGA Tour, Inc. v. Martin, 532 U.S. 661, 121 S.Ct. 1879 (2001).
  • Americans with Disabilities Act, 42 U.S.C.A. Section 12182(a) (1990).


Journalist Brief

This case was about a professional golfer, Casey Martin, who had a disability that made it difficult for him to walk long distances. He asked for permission to use a golf cart during tournaments, but the PGA Tour refused, saying it would change the nature of the game. Martin sued under the Americans with Disabilities Act (ADA), arguing that the PGA Tour was a 'public accommodation' and had to provide reasonable accommodations for his disability. The Supreme Court agreed with Martin. This ruling expanded how the ADA can apply to professional sports and established that the PGA would have to prove that allowing a golf cart would fundamentally change the tournament's nature.


What was the result of PGA Tour, Inc v Martin?

Answer: The Supreme Court ruled in favor of Martin, stating that PGA Tour is a 'public accommodation' under ADA and had to accommodate Martin's disability.

Did the decision impact other professional sports?

Answer: Yes, the ruling expanded how ADA can be applied to professional sports broadly.

Was it ruled that allowing Martin to use a cart would alter the nature of the tournament?

Answer: No, the court found that providing a cart would not fundamentally alter the tournament's nature.

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