Golden Gate University Law Review


Patty Maitland


This Note begins with the background of the ADA and the PGA. Next, this Note provides the factual and procedural background of Martin v. Professional Golf Association Tour, Inc., and then examines the court's analysis of the case. This Note includes a critique of the court's conclusion that the PGA operates its tournaments as a public accommodation and, as such, is not a private club exempt from ADA compliance. Finally, this Note concludes that the Martin court's ruling raises practical concerns for professional sports organizations. These concerns arise because such organizations are now subject to challenges from athletes with debilitating conditions to the extent such challenges require reasonable accommodation under the ADA.