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In 2001, the Supreme Court of the United States ruled in favour of golfer Casey Martin, who sued the PGA Tour under the Americans with Disabilities Act (ADA), asserting that it must accommodate his disability by allowing him to use a golf cart. The Supreme Court, in a 7-2 decision, ruled that the PGA Tour should be viewed as a commercial enterprise and that walking is not a 'fundamental' aspect of golf. Justice Antonin Scalia, known for his wit and sharp legal mind, dissented vehemently, arguing that the court's conclusion distorted the text of Title III and common sense. Scalia's dissent in PGA Tour, Inc. v. Martin is considered one of the funniest and clearest pieces of writing to come down from the Supreme Court.
| Characteristics | Values |
|---|---|
| Case | PGA Tour, Inc. v. Martin |
| Year | 2001 |
| Court | Supreme Court of the United States |
| Decision | 7-2 in favour of Martin |
| Justices dissenting | Antonin Scalia and Thomas |
| Issue | Applicability of the Americans with Disabilities Act of 1990 to professional golf tours |
| Plaintiff's argument | Walking between shots was an important aspect of the game |
| Defendant's argument | Requested to use a golf cart due to a circulatory condition that impaired his ability to walk |
| Scalia's dissent | The Court's decision distorted the text of Title III, the structure of the ADA, and common sense |
| Scalia's key question | Is someone riding around a golf course from shot to shot really a golfer? |
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What You'll Learn
Justice Scalia's dissent in the Casey Martin case
In 2001, the Supreme Court of the United States ruled in PGA Tour, Inc. v. Martin that the Americans with Disabilities Act of 1990 applied to professional golf tours. The ruling was in favour of Casey Martin, a golfer with a circulatory condition that impaired his ability to walk. Martin sued the PGA Tour, which had required all golfers to walk between shots during the third stage of its qualifying tournament, arguing that his disability required him to use a golf cart.
Justice Antonin Scalia wrote the dissenting opinion in the 7-2 decision, joined by Justice Clarence Thomas. Scalia believed that the court should never have been involved in the case and that the PGA Tour was not required to accommodate Martin's request for a golf cart. In his dissent, Scalia wrote:
> "The only thing that could prevent a court order giving the kid four strikes would be a judicial determination that, in baseball, three strikes are metaphysically necessary, which is quite absurd."
He also stated:
> "If one assumes, however, that the PGA TOUR has some legal obligation to play classic, Platonic golf—and if one assumes the correctness of all the other wrong turns the Court has made to get to this point—then we Justices must confront what is indeed an awesome responsibility."
Scalia's dissent in the Casey Martin case is often remembered for its wit and vivid language, showcasing his brilliant writing and judicial restraint. It is considered a classic legal text on sports law and a reflection of his philosophy and greatness as a jurist.
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The Supreme Court's ruling
In 2001, the Supreme Court of the United States ruled on PGA Tour, Inc. v. Martin, a case that examined the applicability of the Americans with Disabilities Act of 1990 to professional golf tours. The ruling, which was decided in a 7-2 vote, sided with golfer Casey Martin, who had a circulatory condition that impaired his ability to walk, against the PGA Tour, which had denied his request to use a golf cart during tournaments.
The PGA Tour, the main organiser of professional golf tours in the United States, had argued that walking between shots was an important aspect of the game and that Martin's use of a golf cart would alter the nature of the competition, giving him an unfair advantage. However, the Supreme Court disagreed, ruling that the PGA Tour should be viewed as a commercial enterprise operating in the entertainment industry rather than as a private club. The Court held that walking was not a "fundamental" aspect of golf and that accommodating Martin's disability by allowing him to use a golf cart would not "fundamentally" alter the game.
Justice Antonin Scalia, known for his quick wit and sharp legal mind, wrote the dissenting opinion, which has been described as one of the funniest and clearest pieces of legal writing to come down from the Supreme Court. In his dissent, Scalia emphasised the difference between what one ought to do and what the law requires, showcasing his profound appreciation for unintended consequences. He argued that the majority's interpretation of the Americans with Disabilities Act distorted the text of Title III and common sense. Scalia contended that the PGA Tour was a professional sporting event staged for entertainment and that the golfers were not "customers" of the PGA Tour or the golf courses but rather part of the entertainment that customers paid to watch.
Scalia also questioned the assumption that the PGA Tour had a legal obligation to adhere to the rules of classic, Platonic golf. He suggested that the PGA Tour could promote a new game with distinctive rules, much like the designated hitter rule in baseball. Scalia asserted that if the new rules were unpopular, people could simply choose not to watch, but ultimately, the rules were arbitrary, and it was not the place of the Supreme Court to deem certain rules as "non-essential".
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Scalia's sarcastic tone
Justice Antonin Scalia, who served on the Supreme Court from 1986 until his death in 2016, was known for his sharp legal mind and quick wit. He was also known for his scathing, witty, and sometimes sarcastic dissenting opinions, which often produced memorable quotes.
In one of his most famous dissents, Scalia argued against the majority's decision in a case involving a disabled golfer, Casey Martin, who used a golf cart. Scalia's writing in this case has been described as not only one of his funniest dissents but also some of the clearest writing to come down from the Supreme Court. In his dissent, Scalia emphasised the difference between what one ought to do and what the law requires, showcasing his profound appreciation for unintended consequences. He also questioned the assumption that walking is a "fundamental" aspect of golf, suggesting that the rules are entirely arbitrary and that there is no basis for the Court to pronounce certain rules as "non-essential".
Scalia's dissenting opinion in the case of King v. Burwell, which involved the interpretation of the Affordable Care Act (also known as Obamacare), provides another example of his sarcastic tone. In this case, Scalia described the majority's reasoning as "interpretive jiggery-pokery" and dismissed their conclusions as "pure applesauce."
In another instance, Scalia ridiculed the majority's reasoning in a 2013 case as "legalistic argle-bargle." Following the Court's ruling in support of gay marriage in Obergefell v. Hodges, Scalia critiqued Justice Anthony Kennedy's majority opinion, stating that he would "hide [his] head in a bag" rather than accept the prose of the majority opinion.
Scalia's sarcastic and witty writing style has been both celebrated and criticised. Some have praised his clear and entertaining writing, while others have found his tone disdainful and offensive. Scalia's dissenting opinions have left a lasting impact on American jurisprudence, and his unique style has certainly contributed to the public's interest in his work.
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The Americans with Disabilities Act
The ADA is divided into five titles or sections, each addressing specific areas of public life. Title II of the ADA prohibits discrimination against qualified individuals with disabilities in all programs, activities, and services provided by state and local governments and their agencies. It also sets detailed standards for public transportation systems and outlines administrative processes for compliance. Title II created a private cause of action for damages against states for conduct violating the Fourteenth Amendment.
The ADA has been amended over the years, with the ADAAA (Americans with Disabilities Act Amendments Act) coming into effect in 2009. The ADA has been the subject of numerous court decisions, including PGA Tour, Inc. v. Martin, where the Supreme Court ruled that professional golf tours fall under Title III and that allowing a golfer with a mobility impairment to use a golf cart did not "fundamentally alter" the nature of golf tournaments. This case highlighted the ADA's requirement for "reasonable modifications" by public accommodations to ensure accessibility for individuals with disabilities.
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The PGA Tour's argument
PGA Tour Inc. v. Martin, 532 U.S. 661 (2001) was a landmark decision by the Supreme Court of the United States that centred on the applicability of the Americans with Disabilities Act of 1990 to professional golf tours. The case involved professional golfer Casey Martin, who had a circulatory condition that impaired his ability to walk, and his request to use a golf cart during the PGA Tour's qualifying tournament, which required golfers to walk between shots.
The PGA Tour, the main organiser of professional golf tours in the United States, argued that walking between shots was an important aspect of the game and refused Martin's request. In response, Martin sued the PGA Tour under the ADA, asserting that they must accommodate his disability by allowing him to use a golf cart.
The Supreme Court, in a 7-2 decision, ruled in favour of Martin, finding that the PGA Tour should be viewed as a commercial enterprise operating in the entertainment industry rather than as a private club. The Court concluded that walking was not a 'fundamental' aspect of golf and that allowing Martin to use a golf cart would not "fundamentally" alter the game.
Justice Antonin Scalia, joined by Justice Thomas, dissented from the majority opinion. Scalia's dissent, known for its wit and clarity, argued that the Court's interpretation of the Americans with Disabilities Act was incorrect. He disagreed with the Court's conclusion that a professional sport is a place of public accommodation and that Martin was a "customer" of the PGA Tour or the golf courses on which it was played. Scalia emphasised that the PGA Tour is a professional sporting event staged for entertainment and that professional golfers are not "customers" but rather the entertainment that customers pay to watch.
Scalia also addressed the Q-School, a competition for entry into the PGA Tour, arguing that it is not a "privilege" offered for the public's "enjoyment" but rather an open tryout similar to casting for a movie or tryouts for other professional sports. He questioned the assumption that the PGA Tour had a legal obligation to adhere to the traditional rules of golf and suggested that it could promote a new game with distinctive rules. Scalia's dissent, while humorous, highlighted his narrow interpretation of the law and his focus on the letter of the law rather than its broader implications.
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Frequently asked questions
'Golf Scalia' refers to Justice Antonin Scalia's dissenting opinion in the case of PGA Tour, Inc. v. Martin, where he argued against the majority ruling that allowed a disabled golfer to use a golf cart during a tournament.
The case involved Casey Martin, a golfer with a circulatory condition that impaired his ability to walk. Martin sued the PGA Tour under the Americans with Disabilities Act, requesting to use a golf cart during tournaments.
Justice Scalia disagreed with the Court's conclusion that a professional sport is a place of public accommodation and that Martin was a "customer" of the PGA Tour or the golf courses. He argued that professional golfers are not "customers" but are themselves the entertainment that customers pay to watch.
The Supreme Court ruled in favour of Martin in a 7-2 decision, allowing him to use a golf cart during PGA Tour events. Justices Scalia and Thomas dissented, with Scalia arguing that the Court's interpretation of the Americans with Disabilities Act was incorrect.
'Golf Scalia' specifically refers to Justice Scalia's dissenting opinion in this case, which is known for its wit and humour. In his dissent, Scalia even questioned the fundamental definition of golf, asking: "Is someone riding around a golf course from shot to shot really a golfer?"
