When presenting the judge with evidence, Martin emphasized that he suffers an immensely larger amount of fatigue and pain than his competitors when walking the course. Martin explained that he is at physical risk of breaking his tibia and/or hemmorhaging with every step he takes and mentions the amount of disrespect it is that they believe giving him a golf cart would put him at a physical and psychological advantage. 

Martin Versus His Able-Bodied Competitors


The Court of Appeals concluded that golf courses are considered places of public accommodation, even during PGA tournaments, and thus subsequently addressed whether the use of a golf cart would alter the nature of the PGA or Nike tour. 


Conclusion from Court of Appeals

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.

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) 

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.

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. 

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