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Disability Law in Sports

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Americans with Disabilities Act (ADA)

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The ADA requires reasonable accommodations be made by both public and private sports facilities and organizations so that individuals with disabilities can participate.

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Section 504 of the Rehabilitation Act of 1973

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Section 504 is a civil rights statute which ensures that individuals with disabilities receive equal access to sports in any program or activity receiving Federal financial assistance, including schools.

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Schmitz v. NCAA

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This case confirmed that the ADA applies to the NCAA and its requirement to provide reasonable accommodation to athletes with disabilities without fundamentally altering the nature of its services.

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Bagenstos v. Michigan High School Athletic Association

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This case clarified that under the ADA, sports organizations must allow athletes with disabilities to compete and may need to modify policies to accommodate them unless it would fundamentally change the game.

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Alexander v. Choate

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The Supreme Court held that Section 504 of the Rehabilitation Act of 1973 requires that individuals with disabilities be provided with meaningful access to benefits, including sports benefits, offered through public programs.

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Endrew F. v. Douglas County School District

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This Supreme Court decision clarified the scope of the IDEA, ensuring that students with disabilities must be given the opportunity to make meaningful progress, which could include participation in sports programs.

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Title IX and Disability Discrimination

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Title IX's gender equality principles apply in ensuring that students with disabilities have equal access to athletic opportunities, including sports participation, in federally funded education programs.

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PGA Tour, Inc. v. Martin

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Supreme Court case that required the PGA to provide a reasonable accommodation to golfer Casey Martin, allowing him to use a golf cart between shots, under the ADA.

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Education Amendments of 1972 (Title IX)

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Although Title IX is known for prohibiting sex discrimination, it also requires that schools offer equal opportunities to students with disabilities in physical education and athletics.

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Parden v. Terminal Railway of Alabama Docks Department

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In this case, it was established that private entities could not use state immunity to avoid being sued under the ADA, ensuring equal access to employment and public accommodations like sports facilities.

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Doe v. National Collegiate Athletic Association

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In this case, it was established that the NCAA must make reasonable modifications to its policies to accommodate athletes with learning disabilities without fundamentally altering the nature of its programs.

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Barnett v. U.S. Air Inc.

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The Ninth Circuit's decision in this case established that modifications or adjustments are reasonable under the ADA only if they don't fundamentally alter the nature of the service, program, or activity, including sports competition.

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Boy Scouts of America v. Dale

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While related to sexual orientation discrimination, this case has implications for how private sports organizations might argue that accommodating a member with a disability would fundamentally alter the nature of the organization or activity.

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Individuals with Disabilities Education Act (IDEA)

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IDEA ensures that children with disabilities have the right to a free appropriate public education, which can include access to physical education and sports programs.

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Halderman v. Pennhurst State School and Hospital

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This landmark case determined that institutions must provide adequate and appropriate services for people with disabilities, impacting how sports programs for the disabled should be operated and funded.

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