PGA Tour, Inc. v. Martin, 532 U.S. 661 (2001)
PGA Tour, Inc. v.
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.
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.