1. Who prevails and why?

2. Why was the PGA so reluctant to allow Martin to use a golf cart, especially considering carts are allowed in other tournaments? Do you agree with the Court’s reasoning that allowing Martin to use a golf cart during tournaments does not give him an advantage? Why or why not?

3. Are there any scenarios in which use of a cart might provide an advantage and, as a result, alter the fundamental nature of the game? Given the Court’s reasoning, would a request to double the size of the hole so that a partially blind competitor could see it when putting fundamentally alter the game?

Martin is a professional golfer who is afflicted with a degenerative circulatory disorder recognized as a disability under the Americans with Disabilities Act (ADA). The disorder causes Martin severe pain due to an obstruction of blood flow between his legs and his heart. The Professional Golf Association (PGA) Tour rules require that players in tournaments walk the course. However, because walking caused Martin pain, anxiety, and generally worsened his condition, he could not walk the course. Although PGA Tour rules prohibit players from using golf carts on the final two stages of the qualifying tournaments, Martin petitioned for a waiver on the basis that he was covered by the ADA. The PGA rejected his request on the grounds that it was not a reasonable accommodation. The PGA asserted that walking was a fundamental part of golf and waiving it for any reason would fundamentally alter the nature of the competition. They argued that the fatigue from walking is a critical factor in the outcome of tournaments. Martin countered by noting that even with the use of a cart he would be required to walk one mile during each round of golf and, because his disability causes him pain and fatigue, the use of the cart would not allow him an advantage over other players.