The PGA argued that the reason for walking the course is to test the athlete’s endurance by increasing energy expenditure and fatigue. The court denied this claim by stating Martin’s disability already created significant fatigue even if not walking.

Why the PGA Denied Martin’s Request

KTS has progressive taken over Martin’s boyd, atrophying his right leg and causing him to be unable to walk a full 18-hole round of golf due to an increased risk of hemorrhaging, blood clot complications, fracturing his tibia, in addition to immense pain, fatigue, and anxiety. 

KTS Impacts on Casey Martin

A nonprofit coalition that was established in 1968 and consists of various sponsors for professional golf tournaments and encompasses about 200 golfers in the PGA Tour. Top scorers of the weekend rounds of golf are awarded prize money.  

PGA Description

The PGA Tour and NIKE Tour have required players to walk all 18 holes of the golf course and do not allow golf carts by the 3rd stage of qualifying rounds. 

Background on PGA Walking Rules

The PGA Tour rules consist of the “Rules of Golf” from the USGA, the “Conditions of Competition and Local Rules” for specific professional tours, and the weekly “Notices to Competitors” for specific events only. 

Establishment of PGA Rules

The PAC-10 Conference and the NCAA waived original rules in order to Martin to be able to participate in tournaments. This waiver led to a Stanford NCAA Championship in 1994. The Q-School (initial first 2 qualifying rounds for the PGA Tour) also waived the hard card rules). 

Martin's Previous Accessibility Waivers

Klippel-Trenaunay syndrome (KTS) is a rare disorder involving the abnormal growth and development of blood vessels, soft tissues, and bones. The condition can lead to severe circulatory complications, such as significant blood flow obstruction.

Klippel-Trenaunay Syndrome

During the third round of the PGA, a qualifying golfer, Casey Martin, requested to use a golf cart to alleviate pain associated with his degenerative circulatory disease. The PGA denied Martin’s request which led him to file an action under Title III of the ADA.

Michigan State University

The issue examined in this case was whether the ADA requires a professional sports organization (the PGA) to make modifications for a participant with a disability.

PGA Tour V. Martin (2001)

PGA TOUR, Inc. v. Martin, 532 US 661 (2001) 

PGA TOUR, Inc. v. Martin 532 US 661 (2001) 

Background of the PGA V. Martin Case

Title III of the ADA requires an entity operating public accommodations to make reasonable modifications to its policies when necessary to afford such accommodations to individuals with disabilities. The entity is exempt from this requirement if they can demonstrate that a modification would fundamentally alter the nature of such accommodations. 

What Section of the ADA the PGA V. Martin Case Regarded

In a 7-2 decision from the SCOTUS, the court found that Title III of the ADA prohibits the PGA from denying equal access to the course on the basis of his disability as permitting him to use a cart would not fundamentally violate the walking rule.

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