Baxter Homeowners Ass'n, Inc. v. Angel
Annotate this CaseAppellant rented second-floor office space and owned one of the upper-floor residential units in the Baxter Hotel. In 2008, the Baxter Homeowners Association (BHA) restricted access to the hotel's elevator by only permitting unit owners and their tenants to access the elevator via swipe key cards. After Appellant filed a complaint with the Montana Human Rights Bureau (Bureau), the BHA board installed a time clock system that would keep the elevator unlocked during business hours and locked at night. Appellant subsequently moved his law office out of the building. Ultimately, a hearing officer with the Bureau concluded that BHA violated Mont. Code Ann. 49-2-304(1)(a) when it failed to provide a reasonable alteration to the elevator to permit disabled persons to have unfettered access to the second floor business offices in the hotel during business hours, awarded $6,000 in damages to Appellant, and denied both parties' requests for attorneys' fees. The Human Rights Commission affirmed. The district court reversed. The Supreme Court affirmed, holding that Appellant did not possess proper standing to file a complaint of discrimination on behalf of his unidentified and potential clients.
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