The Professional Golfers' Association argued walking was fundamental. The fatigue of traversing eighteen holes, they claimed, was a test of athleticism integral to tournament golf. Casey Martin, a professional golfer with a degenerative circulatory disorder in his right leg, argued the rule discriminated against his disability under the Americans with Disabilities Act. The court agreed with Martin.
The decision, delivered on May 29, 2001, was precise. It parsed the concept of "essentiality." Justice John Paul Stevens wrote for the majority. He acknowledged that the rule of walking was applied evenly. But he found it was not an essential component of the competition of golf. The essential challenge was shot-making. The walking was peripheral. It was a rigorous separation of the game's core from its traditional accouterments.
The dissent, authored by Justice Antonin Scalia, viewed the ruling as an intrusion. It substituted a judge's opinion for that of the sport's governing body on what constituted the game's character. The case was never just about a cart. It was a boundary dispute. It asked where the immutable essence of a sport ends and its mutable traditions begin. Martin won the right to ride. The game was forced to formally define what it is actually about.