PGA Tour, Inc. v. Martin

Last updated

PGA Tour, Inc. v. Martin
Seal of the United States Supreme Court.svg
Argued January 17, 2001
Decided May 29, 2001
Full case namePGA Tour, Inc. v. Martin
Citations532 U.S. 661 ( more )
121 S. Ct. 1879; 149 L. Ed. 2d 904; 2001 U.S. LEXIS 4115
Case history
PriorPartial summary judgment granted, Martin v. PGA Tour, Inc., 984 F. Supp. 1320 (D. Or. 1998); permanent injunction granted, 994 F. Supp. 1242 (D. Or. 1998), affirmed, 204 F.3d 994 (9th Cir. 2000); cert. granted, 530 U.S. 1306(2000).
Holding
The PGA Tour is required to adhere to the Americans with Disabilities Act
Court membership
Chief Justice
William Rehnquist
Associate Justices
John P. Stevens  · Sandra Day O'Connor
Antonin Scalia  · Anthony Kennedy
David Souter  · Clarence Thomas
Ruth Bader Ginsburg  · Stephen Breyer
Case opinions
MajorityStevens, joined by Rehnquist, O'Connor, Kennedy, Souter, Ginsburg, Breyer
DissentScalia, joined by Thomas
Laws applied
Americans with Disabilities Act

PGA Tour, Inc. v. Martin, 532 U.S. 661 (2001), was a decision by the Supreme Court of the United States involving the applicability of the Americans with Disabilities Act of 1990 to professional golf tours.

Contents

The PGA Tour, the main organizer of professional golf tours in the United States, had required all golfers to walk between shots during the third stage of its qualifying tournament, which it argued was an important aspect of the game. Golfer Casey Martin, whose circulatory condition impaired his ability to walk, sued the PGA Tour under the ADA, asserting that it must accommodate his disability by allowing him to use a golf cart. The Supreme Court ruled for Martin in a 7–2 decision. [1]

Decision

The Supreme Court ruled in favor of Martin in a 7–2 decision. The court found that the PGA Tour should be viewed as a commercial enterprise operating in the entertainment industry for the economic benefit of its members rather than as a private club. It agreed with the Magistrate Judge Thomas Coffin that the statutory definition of public accommodation included a "golf course", rejecting the Tour's argument that its competitions are only places of public accommodation in the areas open to spectators. The operator of a public accommodation could not, in Judge Coffin's view, create private enclaves within the facility "… and thus relegate the ADA to hop-scotch areas." The finding was originally upheld by the United States Court for the Ninth Circuit.

Justice Antonin Scalia wrote a dissent that concluded by referencing Kurt Vonnegut's story "Harrison Bergeron."

Aftermath

Martin has failed to make it through the PGA Tour Q-school since 2000. He has played in several PGA Tour events, notably in 2004. [2] He lives in Eugene, Oregon and is the men's head golf coach at the University of Oregon. [3]

Related Research Articles

<span class="mw-page-title-main">Americans with Disabilities Act of 1990</span> 1990 U.S. civil rights law

The Americans with Disabilities Act of 1990 or ADA is a civil rights law that prohibits discrimination based on disability. It affords similar protections against discrimination to Americans with disabilities as the Civil Rights Act of 1964, which made discrimination based on race, religion, sex, national origin, and other characteristics illegal, and later sexual orientation and gender identity. In addition, unlike the Civil Rights Act, the ADA also requires covered employers to provide reasonable accommodations to employees with disabilities, and imposes accessibility requirements on public accommodations.

Heart of Atlanta Motel, Inc. v. United States, 379 U.S. 241 (1964), was a landmark decision of the Supreme Court of the United States holding that the Commerce Clause gave the U.S. Congress power to force private businesses to abide by Title II of the Civil Rights Act of 1964, which prohibits discrimination on the basis of race, religion, or national origin in public accommodations.

Tennessee v. Lane, 541 U.S. 509 (2004), was a case in the Supreme Court of the United States involving Congress's enforcement powers under section 5 of the Fourteenth Amendment.

Board of Trustees of the University of Alabama v. Garrett, 531 U.S. 356 (2001), was a United States Supreme Court case about Congress's enforcement powers under the Fourteenth Amendment to the United States Constitution. The Supreme Court decided that Title I of the Americans with Disabilities Act was unconstitutional, insofar as it allowed states to be sued by private citizens for money damages.

Casey Martin is an American professional golfer and the current men's golf head coach at the University of Oregon.

TrafFix Devices, Inc. v. Marketing Displays, Inc., 532 U.S. 23 (2001), was a landmark United States Supreme Court decision in the field of trademark law. The case determined that a functional design could not be eligible for trademark protection, and it established a presumption that a patented design is inherently functional.

<span class="mw-page-title-main">William Canby</span> American judge (born 1931)

William Cameron Canby Jr. is a senior United States circuit judge of the United States Court of Appeals for the Ninth Circuit, sitting in Phoenix, Arizona.

In United States v. Oakland Cannabis Buyers' Cooperative, 532 U.S. 483 (2001), the United States Supreme Court rejected the common-law medical necessity defense to crimes enacted under the federal Controlled Substances Act of 1970, regardless of their legal status under the laws of states such as California that recognize a medical use for marijuana. Oakland Cannabis Buyers' Cooperative was represented by Gerald Uelmen.

<span class="mw-page-title-main">Martha Lee Walters</span> American judge

Martha Lee Walters is an American labor attorney and who served as the 43rd chief justice of Oregon from 2018 to 2022; she was a member of the court from 2006 to 2022. She became the first female justice on the state's highest court in three years when she was appointed in 2006 and the first female chief justice when she was elected by her fellow justices in 2018. A native of Michigan, she worked on the Casey Martin lawsuit against the PGA Tour while in private legal practice.

Jeffrey Michael Quinney is an American professional golfer.

Forest Grove School District v. T. A., 557 U.S. 230 (2009), is a case in which the United States Supreme Court held that the Individuals with Disabilities Education Act (IDEA) authorizes reimbursement for private special education services when a public school fails to provide a "free appropriate public education" (FAPE) and the private school placement is appropriate, regardless of whether the child previously received special education services through the public school.

Dubitante is used in law reports of a judge who is doubtful about a legal proposition but hesitates to declare it wrong. E.g., "Justice X acquiesces in the Court's opinion and judgment dubitante on the question of Constitutional preemption."

United States v. Georgia, 546 U.S. 151 (2006), was a United States Supreme Court case in which the Court decided that the protection of Americans with Disabilities Act of 1990 (ADA), passed by the U.S. Congress, extends to persons held in a state prison and protects prison inmates from discrimination on the basis of disability by prison personnel. Specifically, the court held that Title II of the Americans with Disabilities Act of 1990, 42 U.S.C. §§ 1213112165., is a proper use of Congressional power under the Fourteenth Amendment, Section 5, making it applicable to prison system officials.

C & L Enterprises, Inc. v. Citizen Band, Potawatomi Indian Tribe of Oklahoma, 532 U.S. 411 (2001), was a United States Supreme Court case in which the Court held that the tribe waived its sovereign immunity when it agreed to a contract containing an arbitration agreement.

Access Now, Inc. v. Southwest Airlines Co., 227 F. Supp. 2d 1312, was a decision of the United States District Court on 18 August 2002. It concerned the nature of Title III of the Americans with Disabilities Act of 1990. The court determined that Southwest Airlines website is not a “place of public accommodation” as defined in Title III of the Americans with Disabilities Act of 1990. The case determined that the Southwest Airlines internet website was not in violation of the Americans with Disabilities Act of 1990 as the Americans with Disabilities Act (ADA) is concerned with a physical existence and hence cannot govern what it is in cyberspace. Judge Seitz also explained that the “virtual ticket counter” Southwest Airlines Co’s website was a virtual construct and hence not a “public place of accommodation” and as such “To expand the ADA to cover "virtual" spaces would be to create new rights without well-defined standards".

In United States law, public accommodations are generally defined as facilities, whether publicly or privately owned, that are used by the public at large. Examples include retail stores, rental establishments, and service establishments as well as educational institutions, recreational facilities, and service centers.

This disability rights timeline lists events relating to the civil rights of people with disabilities in the United States of America, including court decisions, the passage of legislation, activists' actions, significant abuses of people with disabilities, and the founding of various organizations. Although the disability rights movement itself began in the 1960s, advocacy for the rights of people with disabilities started much earlier and continues to the present.

United States v. Hatter, 532 U.S. 557 (2001), was a United States Supreme Court case decided in 2001. The case concerned an alleged violation of the Compensation Clause of the United States Constitution when Congress extended Medicare and Social Security taxes to federal judge salaries. Additionally, the case dealt with whether a later increase of federal judge salaries, greater than the new taxes, remedied the potential violation.

Fry v. Napoleon Community Schools, 580 U.S. 154 (2017), is a United States Supreme Court case in which the Court held that the Handicapped Children's Protection Act of 1986 does not command exhaustion of state-level administrative remedies codified in the Individuals with Disabilities Education Act (IDEA) when the gravamen of the plaintiff's lawsuit is not related to the denial of free appropriate public education (FAPE).

US Airways, Inc. v. Barnett, (2002), was a case in the United States Supreme Court that dealt with issues related to the Americans with Disabilities Act of 1990 (ADA) and reasonable accommodations in the workplace. The Court held that even requests for accommodation that might seem reasonable on their face, such as a transfer to a different position, can be rendered unreasonable if they would require a violation of the company's seniority system.

References

  1. PGA Tour, Inc. v. Martin, 532 U.S. 661 (2001).
  2. "PGA Tour profile - Casey Martin" . Retrieved July 16, 2012.
  3. "Casey Martin". University of Oregon Athletics. Retrieved August 9, 2022.