2001
PGA Tour, Inc. v. Martin
A tour golfer with a circulatory condition asked to ride between shots. The PGA Tour said walking was a substantive rule of competition and that waiving it for anyone would fundamentally alter the event. The Court disagreed on both questions it faced: the tour is a place of public accommodation under the ADA, and letting one player ride did not alter the nature of the competition, because the rule the tour was defending was about fatigue rather than about shotmaking.
Why it still matters
It is the case that says a governing body does not get the last word on what its own rules are for. A league can call something essential to the game; a court can look at the evidence and find it is not.
The old rule
A sports governing body wrote the rules of its competition and decided which of them were fundamental. Eligibility and conditions of entry were treated as internal matters, and the question of whether a private tour was even covered by public accommodation law was open.
The legal hinge
Two holdings, and the second is the one with reach. First, the qualifying tournament was open to anyone paying an entry fee, so the tour was a public accommodation and Title III applied. Second, whether a modification is fundamental is a factual question the court decides on the record, not a characterisation the tour supplies.
What people believe
The Court made a sentimental exception for a sympathetic athlete.
What actually happened
The Court applied a statute and examined the record. The finding was that walking was not an essential element of tournament golf and that Martin, even riding, endured more fatigue than a walking competitor. Scalia's dissent argued precisely that courts have no business deciding what is essential to a game — which is the question the majority answered against the tour.
What it cost
Martin litigated for years while his condition progressed, won at every level, and had a brief professional career. He later coached college golf and eventually lost the leg.
Who captured it
Athletes with disabilities across every level of organised sport, and the broader principle that a governing body's account of its own rules is evidence rather than authority.
If it had gone the other way
The ADA's application to professional sport was going to be tested by someone. What is contingent is the record: this case was won on specific factual findings about fatigue in tournament golf, and a different plaintiff in a different sport could have produced a holding that deferred to the governing body instead. The rule that a court decides what is fundamental came from these facts.
Sources
Historical summaries prepared from published opinions and secondary sources. Commentary and analysis, not legal advice.