Legal Brief-PGA TOUR, INC. v. CASEY MARTIN
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Legal brief assignments must follow these formatting guidelines: double spacing, 12-point Times New Roman font, one-inch margins, and discipline-appropriate citations. Page length requirements: 2 pages.
Legal Brief Template
Plaintiff v. Defendant
STATEMENT OF ISSUES:
ARGUMENTS OF THE PLAINTIFFS:
ARGUMENTS OF THE DEFENSE:
HOLDING OF THE COURT:
CASE: PGA TOUR, INC. v. CASEY MARTIN
January 17, 2001, Argued
May 29, 2001, Decided
PRIOR HISTORY: ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT.
DISPOSITION: 204 F.3d 994, affirmed.
Case in Brief
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PROCEDURAL POSTURE: On writ of certiorari to the United States Court of Appeals for the Ninth Circuit, petitioner professional golf tournament sponsor challenged a judgment affirming entry of a permanent injunction ordering petitioner to suspend its “walking rule” and allow respondent to use a golf cart in its tournaments under the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C.S. § 12101 et seq.
OVERVIEW: The court found that golf courses were specifically identified as a public accommodation. 42 U.S.C.S. § 12181(7)(L). Petitioner could not discriminate against either spectators or competitors on the basis of disability. The court found that a waiver of the walking rule for respondent would not work a fundamental alteration of the game. It would not alter such an essential aspect of the game that it would be unacceptable even if it affected all competitors equally. It would not give 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. Nothing in the Rules of Golf forbid the use of carts or penalized their use. Pure chance could have a greater impact on the outcome of elite golf tournaments than fatigue from enforcement of the walking rule. Fatigue was primarily psychological, and stress and motivation were the key ingredients. The ADA’s reasonable modification requirement did not carve out an exemption for elite athletics. Given its coverage of golf courses, applying the ADA to petitioner’s tournaments could not be said to be unintended or unexpected.
OUTCOME: The judgment of the court of appeals was affirmed.
DECISION: Americans with Disabilities Act held to (1) protect access to professional golf tournaments by qualified golfer with disability, and (2) require that golfer be allowed to use golf cart despite rule that contestants must walk.
SUMMARY: Among the ways that an individual could qualify to compete in the professional golf tournaments that comprised two tours, both of which were sponsored by one organization, was by successfully completing a three-stage qualifying tournament known as the “Q-School.” Any member of the public could enter the Q-School, during the third stage of which the use of golf carts was prohibited, by paying $ 3,000 and submitting two letters of reference from, among others, members of the two tours. Although the “Rules of Golf,” which applied at all levels of amateur and professional golf, did not prohibit the use of golf carts at any time, a set of rules that applied specifically to the two tours required golfers to walk the golf courses during tournaments. A golfer with a degenerative circulatory disorder in one leg, who had successfully progressed through the first two stages of the Q-School, made a request, supported by detailed medical records, for permission to use a golf cart during the third stage. After the sponsor refused to review the medical records or to waive the sponsor’s walking rule for the third stage, the golfer filed against the sponsor an action under Title III of the Americans with Disabilities Act (ADA) (42 USCS 12181 et seq.), which in 42 USCS 12182(b)(2)(A)(ii) required an operator of public accommodations to make reasonable modifications in its policies when necessary to afford such accommodations to individuals with disabilities, unless the entity could demonstrate that making such modifications would fundamentally alter the nature of the accommodations. The United States District Court for the District of Oregon entered a preliminary injunction that made it possible for the golfer to use a cart during the third stage of the Q-School and on the two professional tours. A Magistrate Judge denied the sponsor’s motion for summary judgment on the asserted ground that the sponsor was exempt from Title III (984 F Supp 1320). After a trial, the District Court entered a permanent injunction requiring the sponsor to allow the golfer to use a cart in tour and qualifying events (994 F Supp 1242). The United States Court of Appeals for the Ninth Circuit affirmed, concluding that (1) golf courses, including the play areas, were places of public accommodation during the tours’ tournaments, and (2) to permit the golfer to use a cart during the tournaments would not fundamentally alter the nature of the tournaments (204 F3d 994).
On certiorari, the United States Supreme Court affirmed. In an opinion by Stevens, J., joined by Rehnquist, Ch. J., and O’Connor, Kennedy, Souter, Ginsburg, and Breyer, JJ., it was held that (1) the golfer was an individual with a disability as defined in the ADA; (2) Title III was applicable to the sponsor’s treatment of the golfer, with respect to his wish to compete in the tours and the tours’ qualifying rounds; and (3) to allow the golfer to use a cart during the tours’ tournaments would not fundamentally alter the nature of the tournaments, within the meaning of 12182(b)(2)(A)(ii).
Scalia, J., joined by Thomas, J., dissenting, expressed the view that (1) Title III did not apply to the instant case, because the tournaments’ play areas, as opposed to spectator areas, were not places of public accommodation during the tournaments, and (2) in any event, there was no statutory basis on which the court could determine that to allow the golfer to use a cart during the tournaments would not fundamentally alter the nature of the tournaments.
LAWYERS’ EDITION HEADNOTES:
CIVIL RIGHTS §6.5;
— Americans with Disabilities Act — public accommodations — participation in professional golf tournaments SYLLABUS
Petitioner sponsors professional golf tournaments conducted on three annual tours. A player may gain entry into the tours in various ways, most commonly through successfully competing in a three-stage qualifying tournament known as the “Q-School.” Any member of the public may enter the Q-School by submitting two letters of recommendation and paying a $ 3,000 entry fee to cover greens fees and the cost of golf carts, which are permitted during the first two stages, but have been prohibited during the third stage since 1997. The rules governing competition in tour events include the “Rules of Golf,” which apply at all levels of amateur and professional golf and do not prohibit the use of golf carts, and the “hard card,” which applies specifically to petitioner’s professional tours and requires players to walk the golf course during tournaments, except in “open” qualifying events for each tournament and on petitioner’s senior tour. Respondent Martin is a talented golfer afflicted with a degenerative circulatory disorder that prevents him from walking golf courses. His disorder constitutes a disability under the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. § 12101 et seq. When Martin turned pro and entered the Q-School, he made a request, supported by detailed medical records, for permission to use a golf cart during the third stage. Petitioner refused, and Martin filed this action under Title III of the ADA, which, among other things, requires an entity operating “public accommodations” to make “reasonable modifications” in its policies “when . . . necessary to afford such . . . accommodations to individuals with disabilities, unless the entity can demonstrate that making such modifications would fundamentally alter the nature of such . . . accommodations,” § 12182(b)(2)(A)(ii) (emphasis added). In denying petitioner summary judgment, the Magistrate Judge rejected its contention, among others, that the play areas of its tour competitions are not places of “public accommodation” within Title III’s scope. After trial, the District Court entered a permanent injunction requiring petitioner to permit Martin to use a cart. Among its rulings, that court found that the walking rule’s purpose was to inject fatigue into the skill of shot-making, but that the fatigue injected by walking a golf course cannot be deemed significant under normal circumstances; determined that even with the use of a cart, the fatigue Martin suffers from coping with his disability is greater than the fatigue his able-bodied competitors endure from walking the course; and concluded that it would not fundamentally alter the nature of petitioner’s game to accommodate Martin. The Ninth Circuit affirmed, concluding, inter alia, that golf courses, including play areas, are places of public accommodation during professional tournaments and that permitting Martin to use a cart would not “fundamentally alter” the nature of those tournaments.
Barbara D. Underwood argued the cause for the United States, as amicus curiae, by special leave of court.
JUDGES: STEVENS, J., delivered the opinion of the Court, in which REHNQUIST, C. J., and O’CONNOR, KENNEDY, SOUTER, GINSBURG, and BREYER, JJ., joined. SCALIA, J., filed a dissenting opinion, in which THOMAS, J., joined.
OPINION BY: STEVENS
[**1884] [***912] [*664] JUSTICE STEVENS delivered the opinion of the Court.
[***LEdHR1A] LEdHR(1A)[1A] [***LEdHR2A] LEdHR(2A)[2A]This case raises two questions concerning the application of the Americans with Disabilities Act of 1990, 104 Stat. 328, 42 U.S.C. § 12101 et seq., to a gifted athlete: first, whether the Act protects access to professional golf tournaments by a qualified entrant with a disability; and second, whether a [*665] disabled contestant may be denied the use of a golf cart because it would “fundamentally alter the nature” of the tournaments, § 12182(b)(2)(A)(ii), to allow him to ride when all other contestants must walk.
Petitioner PGA TOUR, Inc., a nonprofit entity formed in 1968, sponsors and cosponsors professional golf tournaments conducted on three annual tours. About 200 golfers participate in the PGA TOUR; about 170 in the NIKE TOUR 1;and about 100 in [***913] the SENIOR PGA TOUR. PGA TOUR and NIKE TOUR tournaments typically are 4-day events, played on courses leased and operated by petitioner. The entire field usually competes in two 18-hole rounds played on Thursday and Friday; those who survive the “cut” play on Saturday and Sunday and receive prize money in amounts determined by their aggregate scores for all four rounds. The revenues generated by television, admissions, concessions, and contributions from cosponsors amount to about $ 300 million a year, much of which is distributed in prize money.