Despite his medical condition that caused pain and malfunction of the right leg, Casey Martin was inspired to play professional golf during the PGA tournaments Tour. However, the KTWS prohibited him from walking around the golf course, which is one of the qualifications for participating in the PGA Tour events. Although Martin requested to use a golf cart during the qualification stage, the PGA Tour refused even after reviewing his medical condition.
As such, Martin filed a suit against the PGA Tour for denying him equal access to its tournaments due to his disability. Furthermore, Title III requires the PGA Tour to make rational modifications in its policies when necessary, especially when accommodating people with disabilities. Consequently, the Supreme Court ordered for a permanent injunction against the PGA Tour until Martin was to be allowed to use a cart during the tournaments. Although the PGA appealed, the Court of Appeal still held that Martin was to be allowed to use a cart.
Should a disabled professional participant being allowed to use a golf cart during a PGA Tour tournament change the nature of a tournament while other contestants must walk? Can a person with disability access professional golf tournaments under the Americans with Disabilities Act of 1990.
The PGA Inc. should not deprive any person of the equal and equivalent pleasure of services and privileges since it is an operator of golf courses which are considered places of public accommodation. It is noteworthy that participating in the qualifying tournaments, referred to as Q-School, is among the privileges; therefore, Martin should not be denied equal access to the PGA Tour tournaments based on his disability under Title III. On the other hand, the PGA Tour contended that Martin was not a client of the company under Title III and that his claim was more job-related, thus should have been articulated under Title I. Nevertheless, professional golfers are like independent contractors and not the PGA Tour Inc. employees. Under Title III, Martin was a client of the PGA Tour Inc. because professional golfers are normally required to pay $3000 as a participating fee in the Q-School as well as successive Tour events.
Moreover, the PGA Tour offers two privileges to the public, namely the opportunity to participate in the tournaments and the chance to watch the events. Rational reasoning dictated that Martin would be in an advantage position when using the cart over other participants competing with him who were required to walk. However, there are no rules that forbid or penalize any player for using a cart. Furthermore, the PGA Tour normally allows people to use carts in Senior PGA Tour events. In the case, the PGA Tour claimed that by subjecting players to the same conditions such as walking would establish the spirit of fair competition.
The judgments by the Supreme Court of the United States and the Court of Appeal were right. At the Supreme Court, the vote was 7 to 2, and the two dissenting opinions were Justice Scalia and Justice Thomas.
Justice Scalia’s dissenting opinion stated that the majority opinion misinterpreted Martin’s role as a professional golfer. Moreover, he stated that Martin is a professional athlete selling the PGA Tour golf events and not a customer of the tournament. However, Scalia’s opinion does not hold, as the judgment distorts common sense, the structure of the ADA, and the text of the Title III.
The case should have been ruled in favor of Martin since under ADA standards, the PGA Tour had no right to deny him participation in the events. Moreover, the use of the cart would not have been detrimental to the event.