The Supreme Court held 5/29/01 that Title III of the Americans With Disabilities Act (ADA) covers professional golf tournaments, and thus regulates the rules by which such tournaments are organized and conducted. In this case, the PGA had refused to allow Casey Martin, who suffers from a rare circulatory disease in his leg, to use a golf cart during tournaments. Although the PGA conceded that allowing Martin to use a cart was both a reasonable and necessary accommodation, it argued that doing so would fundamentally alter the nature of the tournaments in which he sought to play. Rejecting that argument, the Court concluded that the PGA’s "walking rule" was not an "essential attribute" of the game of golf. And, noting that the ADA requires evaluation of the disabled person’s needs on an individualized basis, the Court held that in light of Martin’s particular medical condition, allowing him to use a cart would not fundamentally alter the nature of the PGA’s tournaments.
Note that the decision interprets Title III of the ADA relating to public accommodations, while Title I covers employers generally, and has a defense based on "undue hardship of the operation of the business." These provisions use different language, and the Title III defense that a service or facility would be "fundamentally altered" is not at issue in most cases against manufacturers. However, the Court's willingness to second-guess the judgment of the PGA in this context shows how the ADA may be used to interfere with reasonable decisions of employers in other contexts.