You and the Law

Golf Course Website: A Case Analysis of ADA Title III Website Compliance


  • Rebecca J. Kapusta The Ohio State University
  • Leeann M. Lower-Hoppe The Ohio State University


As many sport administrators provide much of their sport content on digital platforms, it is imperative for them to be knowledgeable of Title III of the Americans with Disabilities Act (ADA) of 1990. In the case of Price v. Escalante – Black Diamond Golf Club LLC (2019), Joel Price claimed they were not able to access Black Diamond Golf Club, LLC due to the incompatibility with a screen reader on the organization’s website. The purpose of this law review is to analyze the case and provide implications for practice for practitioners within the field of sport, specifically sport managers overseeing website content administration.

Author Biographies

Rebecca J. Kapusta, The Ohio State University

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Leeann M. Lower-Hoppe, The Ohio State University

Leeann M. Lower-Hoppe is an Assistant Professor of Sport Management in the Department of Human Sciences at The Ohio State University. Lower-Hoppe earned her B.A. in Math-Economics and Business Administration from Anderson University, during which time she competed as a Cross Country and Track athlete and directed intramural sport programming at the university. She completed her M.S. in Sport Management from Baylor University, while assisting with administration of the university’s intramural sport program. Lower-Hoppe received a PhD in Sport Management from The Ohio State University, with a concentration in development through sport, recreation, and play, and specialization in general interdisciplinary quantitative research methodology. While at Ohio State, she acted as the research coordinator for the Learning in Fitness and Education through Sports (LiFE Sports) initiative and assisted the Recreational Sports Department with program evaluation and research.

Lower-Hoppe’s research investigates sport for health and human development through a multi-dimensional framework of organizational effectiveness to extend theory and practice, ultimately advancing the health and development of people through sport. Her largely collaborative research has resulted in 50+ peer-reviewed journal articles, 2 chapters in edited books, and 75+ international, national, and regional professional presentations. Engaging campus and community partners (e.g., OSU Recreational Sports, Special Olympics Ohio, LiFE Sports) is a central feature of Lower-Hoppe’s scholarship, to meet the needs of the community and effectively translate research to practice. Lower-Hoppe serves as an Associate Editor of the Recreational Sport Journal, Topic Editor for Frontiers in Sports and Active Living, and member of three editorial review boards. In addition, she provides research consultation for community sport organizations within central Ohio.


Civil Rights Division. (n.d.). Public accommodations and commercial facilities (title III). U.S. Department of Justice. https://www.ada. gov/ada_title_III.htm

Civil Rights Division. (2012). Americans with Disabilities Act Title III regulations.U.S. Department of Justice. law-and-regs/title-iii-regulations/

ADA National Network. (2021). What are public accommodations?

Americans With Disabilities Act of 1990, 42 U.S.C. § 12101 et seq. (1990).

Houston v. Marod Supermarkets, Inc., 733 F.3d 1323, 1336 (2013). Price v. City of Ocala, 375 F. Supp. 3d 1264 (2019).

Price v. City of Ocala, 375 F. Supp. 3d 1264 (2019).

Price v. Everglades Coll. Inc., 2018 U.S. Dist. LEXIS 117629 (2018).

Price v. Town of Longboat Key, 2019 WL 2173834 (2019).