Discussion 4- BUS LAW 305
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Philosophy
Date
Jan 9, 2024
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Uploaded by LuisS86
PGA Tour, Inc. v. Martin
532 U.S. 661, 121 S. Ct. 1879 (2001)
Supreme Court of the United States
Summary of the case
In a professional golf tournament, players had to walk the course instead of using golf carts. One
participant had a leg condition and asked to use a golf cart during a specific part of the tournament,
providing medical records as evidence. The organizers said no. In response, the participant initiated
legal action under Title III of the Americans with Disabilities Act (ADA), which stipulates that
reasonable accommodations must be provided to individuals with disabilities, "unless the entity could
demonstrate that making such modifications would fundamentally alter the nature of the
accommodations" (PGA Tour, Inc. v. Martin, 2001). The court, in its decision, determined that the use
of golf carts during the tournament "would not give the 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" (PGA Tour, Inc. v. Martin, 2001). Consequently, Martin was granted the
accommodation he had sought.
Rationale for the Court’s Decision
The court's decision was based on two main points. First, they said that the Americans with Disabilities
Act (ADA), which protects people with disabilities in public places, also applied to golf courses and
tournaments like the PGA Tour. So, since Martin was playing on a golf course, he had a right to
accommodations to avoid unfair treatment because of his disability.
Secondly, the court looked at the rules of the PGA Tour. They mentioned something called a "hard
card," which are special rules for PGA Tour events. According to these rules, players usually have to
walk the golf course during tournaments, but not during open qualifying rounds. Since Martin was in a
PGA Tour qualifying event, the court said the PGA Tour's own rules allowed him to use a cart if he
needed it.
The court also argued that letting Martin use a cart wouldn't change the fundamental nature of the PGA
Tour's game. In other words, they believed that helping Martin, who had a disability that could
physically harm him, by allowing him to use a cart wasn't a big enough problem for the PGA Tour to
say no.
Dissenting Opinions
Justice Antonin Scalia disagreed with the majority opinion and expressed his dissent in this case.
According to Scalia, the decision distorted the language of Title III, the structure of the ADA, and
common sense. Title III addresses discrimination in public places, and Scalia argued that a PGA Tour
event didn't qualify as a public place needing accommodation.
He used the analogy of a theater, where the audience is the "customer" at the public place, but the
actors are the "employee" and not entitled to the protection of Title III. Applying this logic to the golf
tournament, Scalia reasoned that Casey Martin was participating to earn money, and it couldn't be
reasonably argued that he was a member of the public seeking accommodation. In Scalia's view, the
event didn't fit the criteria for Title III protection.
Opine as to Whether or Not You Agree with the Outcome of the Case
In considering the majority opinion and Justice Scalia's dissent, I agree with the majority's perspective
that Title III of the ADA should apply to golf courses and tournaments, ensuring reasonable
accommodation to prevent discrimination based on disability. The reasoning that a golf course is a
public place aligns with the spirit of the ADA.
Allowing Martin to use a golf cart as a reasonable accommodation seems justified, considering it
doesn't fundamentally alter the game and adheres to the PGA Tour's own rules during qualifying
rounds. The case sets a precedent for recognizing the needs of individuals with disabilities in
competitive sports, promoting inclusivity.
Implications
The implications of this case could extend to future situations involving individuals with disabilities in
sports or competitive environments. It reinforces the idea that reasonable accommodations should be
considered to ensure equal opportunities. The case may encourage organizations to evaluate their rules
and policies to accommodate individuals with disabilities, promoting a more inclusive approach to
various activities. Additionally, it underscores the importance of considering each case individually to
determine what constitutes a reasonable accommodation without fundamentally altering the nature of
the activity
Biblical Application
As a Christian, I would approach the PGA Tour, Inc. v. Martin case with a perspective grounded in
compassion and justice. I believe in supporting accommodations for individuals with disabilities,
reflecting the Christian principle of treating others with empathy and fairness. “Do nothing from selfish
ambition or conceit, but in humility count others more significant than yourselves.” (Philippians 2:3,
NIV).
Resources
Holy Bible, New International Version. (2011). Zondervan. (Original work published 1973)
PGA Tour, Inc. v. Martin, 532 U.S. 661, 121 S. Ct. 1879 (2001)
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