Case 1: PGA Tour, Inc. v. MARTIN
Facts:
Casey Martin has a degenerative circulatory disorder which constitutes a disability under the ADA. His disorder prevents him from walking, so he made a request to use a golf cart during the PGA qualification tournament onto the professional tours. PGA refused, so Martin filed suit under Title III of the ADA.
“Title III prohibits discrimination on the basis of disability in the activities of places of public accommodations…to comply with the ADA Standards…[and make] reasonable modifications in [its policies] when… necessary to afford such…accommodations to individuals with disabilities, unless the entity can demonstrate that making such modifications would fundamentally alter the nature of such…accommodations."
Under this title, it would be required of PGA to allow Martin to use a golf cart, so the District Court entered a permanent decree against PGA in reference to these circumstances. The purpose of the PGA walking rule is to fatigue the golfers, as there are about four miles in between each hole. However, the court found that Martin would suffer incredible fatigue even just riding four miles in a golf cart, so he should be able to use it.
The Court of Appeals affirmed that, during professional tournaments, golf courses are also places of “public accommodation,” and allowing Martin to use a golf court would not “fundamentally alter the nature of such” tournaments.
Summary:
The court ruled that Casey Martin should be allowed to use a golf cart during PGA tournaments. This decision was made because under Title III of the ADA, places of public accommodations must make reasonable modifications to help those with disabilities so long as those modifications don’t alter the nature of the activity. The court decided that professional golf tournaments are considered places of public accommodation, and as such, PGA must allow Martin to use a golf cart because his use of the golf cart in no way alters the nature of the tournament.
Analysis:
I completely agree with the court’s decision. Martin suffers from a genetic birth defect in his right leg known as Klippel–Trénaunay syndrome. Briefly, this disorder affects the development of blood vessels, soft tissues, and bones. Of course, then, it is difficult for Martin to walk long distances, and the walking in between holes in golf tournaments is extensive. It would be completely unfair to allow Martin to walk with all of the other golfers, because the amount of fatigue that he would suffer from would be much greater than the amount of fatigue endured by the others.
I can almost understand why, at first, PGA didn’t allow him to use a cart. On the outside, Klippel–Trénaunay syndrome only looks like a port-wine stain. If PGA didn’t know the characteristics of his disorder, their decision against him using a cart would be understandable. But upon Martin defending himself, PGA absolutely should have immediately accommodated him.
Influences:
Martin’s socioeconomic status definitely gave him a leg up in this court ruling. He earns roughly $170,000 a season. Therefore, he was wealthy enough to afford resources to defend his case, whereas a less wealthy plaintiff may not have had the same luxury. Also, with such a large following, there would be a major uproar if the court did not rule in his favor.
Case 2: S.S. v. WHITESBORO CENTRAL SCHOOL DISTRICT
Facts:
Plaintiff “S.S.” is a high school freshman who suffers from severe anxiety attacks when out in public. Upon joining Whitesboro High School’s swim team, her parents informed the school and Defendant Cole (her swim team coach) of her anxiety attacks, and gave instruction regarding what to do upon onset.
Severe onsets of anxiety would trigger thoughts of drowning in S.S., which prevented her from being able to stay in the pool for the long periods of time required by the coach. She would need to exit the pool to ease her anxiety. Her parents warned Defendant Cole and the school of this accommodation; however, whenever she exited the pool during practice, she was “verbally attacked” by her coach, who told her that she would be kicked off the swim team if she didn’t reenter the pool.
S.S. also had attacks during time trials and swim meets, and on numerous occasions ran out of the pool in the middle of a meet to ease her anxiety. This caused her coach to threaten to kick her off the team numerous times. Defendant Cole stated that “she did not get paid to baby-sit.”
Defendant Cole’s actions caused S.S. to have to leave school for the rest of the fall semester due to her disability. Even though S.S. repeatedly reported to the school district about the situation and the affects it had on her academics and emotional state, Defendant Cole still made no effort to accommodate her mental disability.
Plaintiff S.S. requested monetary damages, injunctive relief, and reasonable accommodations as relief for her injuries. The court ruled in favor of the defendant school district, holding that S.S. was not qualified to be on the swim team, as she must be able to swim when called upon. She also didn’t show what reasonable accommodations the school district could make for her disability.
Summary:
The court ruled in favor of Defendant Cole and the school district. This decision was made because Plaintiff S.S. was unable to meet the requirements of being part of the swim team. The most important qualification of being on the swim team is being able to swim when asked to do so, and due to her disability, she did not meet this requirement. She also failed to provide any proper, reasonable accommodations that the school district could make in order to allow her to participate in the sport.
Analysis:
I agree with the court’s decision. If S.S. is unable to swim at any given time, she does not meet the qualifications for being on the swim team. However, I do believe this situation could have been handled much more compassionately. S.S. did complain many times that her coach’s lack of compassion for her disability caused her to suffer emotionally and academically. The coach could have at least spoken to her kindlier, or even allowed her to practice with the team and just not compete.
In the future, the coach and school district should probably approach a situation like this differently, as their behaviors towards the student (and lack thereof) were insensitive. Although no laws were broken, S.S. did have to drop out of school because of all of this, and that’s just not fair.
Influences:
Some may argue that the plaintiff’s gender had an effect on the court’s ruling. Maybe if she were a male, the court would have been more willing to rule in S.S’s favor due to possible gender bias.
Plaintiff’s physical abilities also have a major effect on the court’s ruling. If the plaintiff were a record-setting, medal-winning swimmer, the court may have been more empathetic to her case, deciding that her mental disability truly is getting in the way of her physical abilities, and the school must work harder to accommodate her.