Private clubs' facilities are exempt from Title III of the ADA and the ADA Standards as long as they are not open to the general public. An entity is a private club for purposes of the ADA if it is a private club under Title II of the Civil Rights Act of 1964, which prohibits discrimination on the basis of race, color, and national origin by public accommodations.
Courts have been most inclined to find private club status in cases where --
1) Members exercise a high degree of control over club operations.
2) The membership selection process is highly selective.
3) Substantial membership fees are charged.
4) The entity is operated on a nonprofit basis.
5) The club was not founded specifically to avoid compliance with Federal civil rights laws.
Private clubs lose their exemption if they are made available for use by nonmembers as places of public accommodation. So for example, if a private club hosted a golf tournament open for the public to attend, then all of the facilities for the event would become public accommodations during the tournament and subject to ADA Title III compliance.