Case brief

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Read and brief PGA Tour, Inc. v. Casey Martin. Also, comment on the court’s decision. In your opinion do you agree or disagree with the outcome? Justify your answer.

Summarize another sports-related case dealing with the ADA in which the courts did not rule in favor of the individual.

use the example attachment for format:

Case briefs should be one page in length (single spaced), use 12-point Times New Roman font

Case Citation:
Plaintiff v. Defendant, Volume Source Page (Court Date)
(e.g., Allen v. Dover Co-Recreational Softball League, 148 N.H. 407 (2002))
Body (one paragraph for each element):
Facts: Outline the pertinent facts in the case, highlighting those with bearing on the court’s final decision.
Issues: Present the specific legal question(s) before the court. If the court raised/addressed multiple issues, address each separately.
Your issues should be concisely stated in question form and specific, not generalizations.
Holding (Decision): Outline the final decision of the court in this case. Answer the questions that you stated in the issues section.
Rationale: Your brief should conclude with a summary of the explanation by the court of its findings. Why did the court answer the
legal question in the manner that it did?
Additional Questions/Discussion: In some of the case briefs additional discussion questions have been provided for you to answer.
Provide a brief (no more than one page, single spaced) answer to these questions. You must justify and support your answers.

PGA Tour, Inc. v. Martin, 532 U.S. 661 (2001) 1

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

Elizabeth Valade

Southern New Hampshire University

Sport Law

SPT-610

Dr. Brent Estes

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PGA TOUR, INC. V. MARTIN, 532 U.S. 661 (2001) 2

PGA TOUR, INC. V. MARTIN, 532 U.S. 661 (2001) CASE BRIEF

Facts
Casey Martin (“plaintiff”) was born with a birth defect of circulatory condition in his

lower right leg that prevented him from walking golf courses to compete. His disorder
constitutes a disability under the Americans with Disabilities Act of 1990 (ADA, n.d.). The rules
in the PGA Tour (“defendant”) do not allow for the use of a cart during tour events. In 1997,
while attempting to qualify for the PGA Tour through the Q-course, Mr. Martin petitioned the
PGA to allow him to use a cart during the third and final stage. The PGA Tour denied his request
stating that his use of the cart would fundamentally alter the game. Mr. Martin filed a suit against
the PGA Tour based on discrimination.

In November 1997, Mr. Martin filed a lawsuit with the U.S. District Court in Oregon.
During the hearing the PGA Tour argued that the District Court did not have jurisdiction over the
Tour (which is headquartered in Florida), and that the Tour was a private organization to which
the ADA did not apply. The U.S. District Court granted a temporary injunction to Mr. Martin
allowing him to use a cart until a trial could occur in February 1998. In February 1998, the court
ruled that the ADA required the PGA Tour to allow Martin to ride a cart during competition. The
PGA Tour appealed, and the case was referred to the Ninth Circuit. In May 1999, the Ninth
Circuit began hearing the case and in March 2000, the Ninth Circuit released its opinion
affirming the decision of the District Court and Martin’s right to a cart under the ADA. The PGA
Tour brought its appeal to the United States Supreme Court.

Issues
Did the PGA Tour discriminate against Martin by not allowing him to use a golf cart to

compete in PGA Tour events?
Does the PGA Tour compete on a public accommodation which would require the

organization to follow the Title III of the ADA?

Holding
On January 17, 2001, the Supreme Court heard oral arguments in the case of PGA Tour v

Martin. On May 29, 2001the United States Supreme Court handed down a 7-2 decision in favor
of Martin. The Court affirmed the Ninth Circuit opinion and held that Title III prohibited the
Tour from denying Martin use of a cart on its tours.

Rationale
As a rule, Title III prohibits discrimination based on disability in the full and equal

enjoyment of “goods, services, facilities, privileges, [or] advantages” of any public
accommodation by any person who “owns, leases (or leases to), or operates a public
accommodation (42 U.S. code § 12182 – Prohibition of discrimination by public
accommodations, n.d.). Golf Courses are listed as one of the twelve extensive categories. The
court found that golf tours and qualifying rounds are public accommodations covered by the
ADA as the PGA Tour offered people to either be spectator or competitors. By paying for his
entry, Mr. Martin was a customer. The US Supreme Court ruled that lower the use of a cart was a
reasonable accommodation and not a fundamental alteration of the game.

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PGA TOUR, INC. V. MARTIN, 532 U.S. 661 (2001) 3

Discussion
In the case Pryor V. NCAA (2002), the court ruled in favor of the NCAA. The Third

Circuit Court of Appeals determined that the NCAA did not violate the ADA. Pryor was
diagnosed with a learning disability. Under the NCAA rules, a student that has a learning
disability will be granted an additional year of eligibility if they complete 75% of their degree
requirements at the completion of their fourth year in college. At the time of the lawsuit, Pryor
had not entered her fourth year at San Jose State, and she had the ability to regain her eligibility
based up the NCAA rules governing student athletes with disabilities.

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PGA TOUR, INC. V. MARTIN, 532 U.S. 661 (2001) 4

References

Cotten, D. J., & Wolohan, J. T. (2017). Law for Recreation & Sport Managers (8th ed). Dubuque, IA:

Kendall Hunt.

PGA Tour, Inc. v. Martin, 532 U.S. 661 (2001) https://heinonline-

org.ezproxy.snhu.edu/HOL/CaseLawAuth?

cid=4470833&native_id=4470833&rest=1&collection=fastcasefull

Pryor V. NCAA, 288 F.3d 548 (3d Cir. 2002) https://caselaw.findlaw.com/us-3rd-

circuit/1302741.html

42 U.S. code § 12182 – Prohibition of discrimination by public accommodations. (n.d.). LII / Legal

Information Institute. https://www.law.cornell.edu/uscode/text/42/12182

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