Casey Martin, a professional golfer, has Klippel–Trénaunay–Weber syndrome, a congenital circulatory disorder causing severe pain, weakness, and risk of hemorrhage in his right leg. The condition substantially limits his ability to walk long distances. Martin sought to compete on the PGA Tour and in its three-stage Qualifying School (Q-School). The PGA Tour operates tournaments and Q-School rounds at golf courses around the country and enforces a rule generally requiring players to walk during competition; carts are permitted for spectators and in some other PGA contexts (e.g., the Senior Tour and early Q-School stages), but not in regular Tour events and the final Q-School stage. Martin requested to use a golf cart as a reasonable modification under Title III of the ADA. The Tour denied the request, claiming walking was an essential part of tournament golf and that allowing a cart would fundamentally alter the nature of competition by removing the fatigue that walking imposes as a test of skill and endurance. Martin sued under Title III in federal court in Oregon. After a bench trial, the district court found that Martin's disability caused him to expend more energy than other players even with a cart and that walking was not an essential feature of championship golf. The court ordered the PGA Tour to allow Martin to use a cart. The Ninth Circuit affirmed, and the Supreme Court granted certiorari.
Does Title III of the ADA apply to PGA Tour tournaments and qualifying events, and if so, does the ADA require the PGA Tour to modify its walking rule to allow a professional golfer with a mobility disability to use a cart, where the modification would not fundamentally alter the nature of the competition?
Title III of the ADA prohibits discrimination on the basis of disability by private entities that own, lease, or operate places of public accommodation. 42 U.S.C. § 12182(a). Covered entities must make reasonable modifications in policies, practices, or procedures when necessary to afford goods, services, facilities, privileges, advantages, or accommodations to individuals with disabilities, unless the entity demonstrates that making such modifications would fundamentally alter the nature of those goods, services, facilities, privileges, advantages, or accommodations. 42 U.S.C. § 12182(b)(2)(A)(ii). Places of public accommodation expressly include golf courses and places of exhibition or entertainment. 42 U.S.C. § 12181(7). Determining whether a modification is reasonable and whether it would fundamentally alter the nature of the activity requires an individualized, fact-specific inquiry.
Yes. Title III applies to PGA Tour tournaments and qualifying events, which are operated at places of public accommodation. Allowing Casey Martin to use a golf cart is a reasonable modification that does not fundamentally alter the nature of tournament golf. The ADA therefore requires the PGA Tour to grant the accommodation.
The Court, in a 7–2 opinion by Justice Stevens, first held that the PGA Tour operates places of public accommodation during its events because it leases and controls golf courses and venues that are specifically identified in the ADA's coverage (golf courses and places of exhibition or entertainment). Title III protects "any individual," not only customers, and extends to participation in the "privileges" and "advantages" a public accommodation offers, which include the opportunity to compete in a professional tournament. Thus, Title III applies to professional participants as well as spectators. Turning to the modification request, the Court applied the statute's requirement of reasonable modifications absent a fundamental alteration. It stressed that the ADA demands an individualized inquiry rather than categorical deference to a sport's rules. The district court's factual findings—based on live testimony and expert evidence—showed that (1) the Tour's walking rule aimed primarily at injecting fatigue into competition; (2) walking is not an essential attribute of the sport of golf itself, as illustrated by widespread use of carts in recreational play, allowance of carts in some professional contexts (e.g., the Senior Tour and earlier stages of Q-School), and the fact that the essence of golf skill lies in shot-making; and (3) Martin's condition caused him to suffer greater fatigue than other players even when using a cart, meaning a cart would not confer a competitive advantage. On these facts, permitting a cart did not fundamentally alter the nature of tournament golf. The accommodation concerned a policy (walking) peripheral to golf's core skills and did not affect the course's physical setup, scoring, or rules governing play of the ball. The Court rejected the Tour's argument for blanket judicial deference to "rules of the game," explaining that while sports bodies' views on a sport's essential features merit respectful consideration, they are not dispositive under the ADA. The majority also noted the statute's breadth and purpose to integrate individuals with disabilities into public life, including professional contexts. Justice Scalia, joined by Justice Thomas, dissented, arguing that the walking rule defines the nature of professional golf and that courts should not second-guess sports organizations' competitive rules, but the majority concluded the ADA requires more than uncritical acceptance of such assertions.
PGA Tour v. Martin is a foundational ADA case that clarifies three major points. First, Title III covers professional competitions operated at public accommodations and protects participants, not just patrons. Second, courts must conduct an individualized inquiry into requested modifications and whether they would fundamentally alter the activity, resisting categorical or talismanic deference to institutional rules. Third, the decision delineates the boundary between an activity's essential nature and ancillary policies, offering practical guidance for businesses and organizers evaluating accommodation requests in high-stakes settings. For law students, the case illustrates statutory interpretation, the mechanics of Title III's reasonable-modification and fundamental-alteration framework, and how evidentiary findings (on advantage, fatigue, and the core of a sport) drive outcomes. It also informs broader civil rights practice where private entities operate public accommodations and must balance uniform rules with individualized accommodations.
PGA Tour v. Martin affirms that Title III's promise of equal access reaches the rarefied world of professional sports when those events are conducted at public accommodations. The decision carefully balances competitive integrity with disability rights by distinguishing between the essence of an activity and ancillary policies that can be modified without changing the game itself.