Maffit v. City of Helena, 479 P.3d 961

MILP, a nonprofit center for independent living, requested city funding in 2014 for a van to transport people with disabilities; the Helena Area Transportation Advisory Committee (HATAC) ranked MILP first.
In February 2015 MILP and its CEO filed an HRB complaint alleging the City’s new bus routes segregated persons with disabilities (Initial Complaint).
At a subsequent Transit Development Plan meeting, the City Commission placed a fixed-route project ahead of MILP’s request (departing from HATAC’s recommendation); MDOT nonetheless funded MILP’s van request.
MILP filed a Retaliation Complaint with the HRB alleging the City lowered the funding priority in direct retaliation for the Initial Complaint; the HRB found no reasonable cause and held a corporation lacks standing under § 49-2-301 to bring a retaliation claim.
MILP sued in District Court; the City moved to dismiss MILP as a plaintiff under M. R. Civ. P. 12(b)(6). The District Court dismissed MILP, ruling § 49-2-301 permits retaliation claims only by natural-person “individuals.” MILP appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether non-human entities (e.g., corporations/advocacy groups) may bring retaliation claims under § 49-2-301, MCA	MILP: MHRA’s broad remedial purpose, definitions and enforcement provisions show retaliation claims should be available to "persons," including organizations	City: § 49-2-301 expressly prohibits retaliation against an "individual;" "person" (which includes corporations) is used elsewhere—legislature intentionally limited retaliation protection to natural persons	Held: § 49-2-301 unambiguously protects only an "individual" (a natural person); non-human entities lack standing to bring retaliation claims under that provision (affirmed)
Entitlement to attorneys’ fees under the private-attorney-general doctrine following dismissal	MILP: sought fees as prevailing private attorney general	City: no underlying statutory claim succeeded, so fees not recoverable	Held: Fees denied—MILP did not succeed on the underlying claim, so private-attorney-general fees unavailable

Hein v. Sott, 353 P.3d 494 (de novo review of motion to dismiss)
Bates v. Neva, 339 P.3d 1265 (interpretation of MHRA and statutory construction principles)
Gannett Satellite Info. Network, Inc. v. State, 201 P.3d 132 (plain-language statutory construction governs)
Formicove, Inc. v. Burlington N., Inc., 673 P.2d 469 (presumption the legislature does not perform idle acts)
Lyman Creek, LLC v. City of Bozeman, 450 P.3d 872 (an implied cause of action cannot override a clear statute)
Faust v. Util. Sols., LLC, 173 P.3d 1183 (private-attorney-general fees require success on the merits)