Exploring Disability Rights: PGA Tour, Inc. v. Martin

PGA Tour, Inc. v. Martin

Facts of the Case:

In the court case of PGA Tour, Inc. v. Martin, Martin was a golfer who suffered from a circulatory disorder that prevents him from walking properly. Circulatory disorders diminish the flow of blood and oxygen supply throughout your body, so it was difficult for Martin to walk the lengths of a golf course. In order to gain entry into professional golf tours, Martin had to qualify at a competition known as “Q-School.” Competing in the stages of Q-School was not an issue for Martin until the last stage when none of the competitors were permitted to use a golf cart. He was refused the use of a golf cart during the third stage, so he filed a complaint under Title III of the American’s with Disabilities Act (PGA Tour, Inc. v. Martin, 2001).

Decisions:

The petitioner of PGA Tour, Inc. believed that the golf tournament was supported by the American’s with Disabilities Act because it was a “private club or establishment” (PGA Tour, Inc. v. Martin, 2001). On the other hand, the

Magistrate Judge disagreed and ruled that the tournament and golf course was a place of public accommodation because it was being used as a commercial enterprise for entertainment and economic benefits. Due to the golf course being public, the petitioner could not make certain parts considered “private,” so Martin was protected under Title III of the ADA. The Court held that Martin using a golf cart in the third stage would not “alter the nature of the game.” Martin’s circulatory disability already exhausts him enough, so the walking rule should not apply to him since the sole purpose of it is to fatigue the players.
Analysis:
The Court’s decision was adequate in providing for the rights of Casey Martin. Martin was a successful golfer with a circulatory disability that physically distressed him. Since he was already fatigued more than usual, the walking rule for the third stage should not apply to him. Additionally, golf courses are listed as public areas under the ADA, so PGA Tour, Inc. cannot claim certain things as private, like the Q-School. Title III of the ADA states that public accommodations must, “make reasonable modifications in policies, practices, and procedures that deny equal access to individuals with disabilities, unless a fundamental alteration would result in the nature of the goods and services provided,” so Martin was true to file a complaint for the disadvantages he was unlawfully given by PGA Tour, Inc. (Americans with Disabilities Act of 1990). He was not given equal access from the walking rule in the third stage of Q-School because the petitioner would not modify the rules, thus his rights were being denied.

Kuketz v. Petronelli
Facts of the Case:
In the court case of Kuketz v. Petronelli, Stephan B. Kuketz has been a paraplegic since 1991. Kuketz was a well known wheelchair racquetball player and wanted to join the “A’ league roster. In order for him to play competitively, he needed an extra bounce of the ball before returning it, while the players without disabilities were only allowed one bounce. After discussing with the other “A” league players, the general manager, Roslyn Petronelli, told Kuketz that he would not be able to play with them under safety concerns he cited, but gave him two additional options. The two options were for him to play in a lower-level league by following the rule of only one bounce, or to play in a wheelchair league that she would help him start up. Kuketz did not agree with Petronelli’s decision and filed a complaint under Title III of the American’s with Disabilities Act (Kuketz v. Petronelli, 2005).
Decisions:
In the conclusions of this case, a Superior Court judge ruled that the general manager and the teammates of the racquetball league were not required to allow Kuketz two bounces because it would “fundamentally alter the nature” of the racquetball competition under Title III of the ADA.

Kuketz disagreed and appealed, stating that the judge made a mistake in ruling that his modification would create a “fundamental alteration of the game” (Kuketz v. Petronelli, 2005). In the case of PGA Tour Inc. v. Martin, allowing the use of the golf cart did not skew the substance of the competition, but allowing Kuketz to use two bounces would be inconsistent with the game strategies, thus creating a totally new game. Under the ADA, Kuketz had rights to an individual assessment of the situation due to his disability, but even after that, the racquetball league did not have to individually assess Kuketz due to his modification of the game fundamentally altering the

game.
Analysis:
The Court’s ruling of Kuketz v. Petronelli was fair in following the guidelines of the ADA. Even though Kuketz had a disability, the ADA still did not allow the changing of the already instituted rules of racquetball. The ADA states that “A modification is not required if it would "fundamentally alter" the goods, services, or operations of the public accommodation” (Americans with Disabilities Act of 1990). With the public accommodation being the game of racquetball in this case, Kuketz could not change the rules of the game based on his disability. Kuketz was given two additional options from the general manager, Petronelli, with one of them being starting their own wheelchair league, and I believe he should’ve accepted that with gratitude. Petronelli was lawfully accommodating for Kuketz under Title III of the ADA and the court’s ruling was accurate to go against Kuketz’s misinterpretation of what he has the right to. Other provisions were given to Kuketz that could have helped him excel greatly in his talents at a professional level like he desired.