Bates v. Neva
Annotate this CaseAppellant Laura Lee Neva sued Appellee Jim Bates, arguing he violated Montana's Human Rights Act by halting necessary repairs to a commercial building she rented from him because she rebuffed his sexual advances. In her complaint to the Human Rights Commission, Appellant alleged violation of the Public Accommodations Provision but made no mention of the Real-Estate Transaction Provision. The Commission nevertheless found that Appellee violated the Real-Estate Transaction Provision by sexually harassing Appellant while she was leasing the space from him. The District Court reversed that decision, holding that the Commission’s action violated Appellee's right to due process. The issue on appeal to the Supreme Court was whether the District Court erred in its conclusion that Appellee was not afforded due process when Appellant brought claims under section 49-2-304 of the Act, but that the Commission did not find he violated section 49-2-305. The Supreme Court reversed the lower court, finding that the essential difference between a 49-2-304 claim and a 49-2-305 claim was the setting of the discrimination: a place of public accommodation as opposed to a real-estate transaction. "The setting here was fully litigated, as was the discrimination- Bates' sexual harassment of Neva." The Court concluded Appellee understood the issues as was afforded full opportunity to justify his conduct. Therefore, his due process rights were not violated.
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