CEnTech Corp. v. Sprow

Summary

The Supreme Court of Montana held that Heidi Sprow did not plead sex-based wage discrimination regarding her full-time employment. The court concluded that the administrative hearing examiner and Human Rights Commission exceeded their authority by introducing and adjudicating the full-time wage-disparity issue, which was not included in the timely complaint or pre-hearing order. The court affirmed the district court's reversal of the agency decision in Sprow's favor.

Holdings

1. Sprow did not plead sex discrimination relating to her full-time wages. Her complaint referred to full-time employment only as background and challenged the disparity between her part-time wage and the wage of a male part-time coworker.
2. The Hearings Bureau erred by inserting the full-time wage-discrimination issue into the pleadings, and the Human Rights Commission erred by remanding the case to provide CEnTech an opportunity to defend an issue that had not been pleaded.

Questions Presented

1. Whether Sprow's complaint pleaded sex discrimination with regard to her full-time employment and wages.
2. Whether the Hearings Bureau and Human Rights Commission acted beyond their authority by adding and adjudicating the unpleaded full-time wage-discrimination issue.

Disposition

affirmed