Saturday, November 9, 2013

PGA Tour, Inc. v. Martin case brief

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


CASE SYNOPSIS
On writ of certiorari to the United States Court of Appeals for the Ninth Circuit, petitioner professional golf tournament sponsor challenged a judgment affirming entry of a permanent injunction ordering petitioner to suspend its "walking rule" and allow respondent to use a golf cart in its tournaments under the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C.S. § 12101 et seq.

DISCUSSION

  • The court found that golf courses were specifically identified as a public accommodation. 42 U.S.C.S. § 12181(7)(L). 
  • Petitioner could not discriminate against either spectators or competitors on the basis of disability. 
  • The court found that a waiver of the walking rule for respondent would not work a fundamental alteration of the game. 
  • It would not alter such an essential aspect of the game that it would be unacceptable even if it affected all competitors equally. 
  • It would not give respondent an advantage over others and fundamentally alter the character of the competition. Use of carts was not itself inconsistent with the basic character of the game. 
  • Nothing in the Rules of Golf forbid the use of carts or penalized their use. 
  • Pure chance could have a greater impact on the conclusion of elite golf tournaments than fatigue from enforcement of the walking rule. 
  • Fatigue was primarily psychological, and stress and motivation were the key ingredients. 
  • The ADA's reasonable modification requirement did not carve out an exemption for elite athletics. 
  • Given its coverage of golf courses, applying the ADA to petitioner's tournaments could not be said to be unintended or unexpected.

CONCLUSION
The judgment of the court of appeals was affirmed.


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