• Matteson Landau

Looking Back at PGA Tour v. Casey Martin


Photo Credit: Golf.com


On Friday October 15th, 2021, Casey Martin had the lower half of his right leg amputated. [1] Casey Martin is the head coach of the Men’s Golf team at the University of Oregon, a former member of the PGA tour, and was college teammates with Tiger Woods at Stanford. Outside of coaching success, Martin’s name has largely been out of the news for nearly 20 years, but this weekend golf fans were reminded of his past. Martin is best known for suing the PGA Tour in 1997, filing litigation which was seen by many at the time as damaging to the integrity of the game. [2]


Casey Martin has suffered from Klippel-Trènaunay-Weber syndrome since birth. KTW is a “congenital circulatory disorder,” and effects his ability to walk, especially significant distances. [3] In October 2019 he suffered a minor accident while pulling his garbage can in off the curb, and due to the weakened condition of his legs, broke his right tibia. Since then, he has fought a two-year battle to save his leg, as amputation above the knee was risky, but due to KTW syndrome the fracture in his leg never healed. [3] Luckily, Martin’s surgery last week was successful and he “has a good shot at an effective prosthesis.” [4] Martin has been quoted frequently as being lucky and grateful that his leg survived this long as he thought it was his “destiny” to lose it eventually. [4]


But, while the golf industry reports and celebrates Martin’s successful surgery, it also brings about an opportunity to re-evaluate the stances taken in his lawsuit, ultimately decided by the U.S. Supreme Court in 2001. Martin sued in US District Court in Oregon for violation of Title III of the ADA (Americans with Disabilities Act) after his request to use a golf cart at PGA Tour Q-School was denied despite following proper ADA procedure. [5] At trial, the PGA Tour argued it had a right to make and enforce rules for its players, and brought in high profile witnesses such as Arnold Palmer and Jack Nicklaus to testify “walking was a fundamental part of golf.” [2] To the general public, Martin was portrayed as weak and attempting to thwart the game to his own advantage. However, judges at all three levels of Federal court disagreed and issued an injunction which allowed Martin to use a golf cart at PGA Tour events. Ultimately, the U.S. Supreme Court ruled “Title III of the Americans with Disabilities Act prohibited the PGA from discriminating against either the spectators or competitors on the basis of disability,” noting that Title III specifically identifies golf courses as a “public accommodation.” [5]


In a game that has been historically exclusive by race, sex, and ability, Martin’s fight for progress represented an important step toward increasing the accessibility of both professional and amateur golf. And how credible was the pushback from the PGA Tour that they would “lose the game of golf forever the way we know it?” [2] Martin’s specific use of a golf cart has only been repeated by one other Tour player, John Daly, who competed in the 2019 PGA Championship at age 53 and invoked ADA for use of a golf cart. [6] However, the farther-reaching effects of a Supreme Court ruling which bound the PGA Tour to adhere to ADA Title III opened up opportunities in golf at all levels. Change did not occur overnight, but door to opportunity was opened. In 2015, the US Disabled Golf Association, or USDGA, was founded by Jason Faircloth, “the first and only American to play in the Disabled British Open” In 2018 the first ever US Disabled Open was held in Florida, which represented the first event to ever obtain world rankings for golfers with disabilities by the USGA. [7] Overall, Casey Martin’s success on the course and in the courtroom has played a pivotal role in driving the sport of golf toward constitutionally bound equal accessibility.


[1] https://golf.com/news/casey-martin-sued-pga-tour-cart-use-loses-right-leg-amputation/

[2] https://www.lyingfour.com/conversations-blog/2021/5/27/gmfy37k9owf5ejxmy6z0o7b4d6gbe9

[3] https://www.cbc.ca/sports/golf/casey-martin-fight-saving-leg-1.5514829

[4] https://www.si.com/golf/news/casey-martin-has-right-leg-amputated-due-to-rare-circulatory-disease

[5] https://www.lexisnexis.com/community/casebrief/p/casebrief-pga-tour-inc-v-martin

[6] https://www.golflink.com/about_35344_pga-tour-when-can-professional-golfers-use-golf-carts.html

[7] http://www.usdga.net/about/