Nevada State Civil Rights Complaint (NEOA, Public Accommodations, and Parallel Federal Claims)

NEVADA CIVIL RIGHTS COMPLAINT — NEVADA EQUAL EMPLOYMENT OPPORTUNITY ACT, PUBLIC ACCOMMODATIONS, AND PARALLEL FEDERAL CLAIMS

TABLE OF CONTENTS

1. Caption
2. Introduction
3. Parties, Jurisdiction, and Venue
4. Administrative Exhaustion (NEOA Counts)
5. Common Factual Allegations
6. Count I — NEOA Discrimination (NRS § 613.330)
7. Count II — NEOA Hostile Work Environment / Harassment (NRS § 613.330)
8. Count III — NEOA Retaliation (NRS § 613.340)
9. Count IV — Public Accommodations Discrimination (NRS § 651.070, § 651.090)
10. Count V — Nevada Pregnant Workers' Fairness Act (NRS § 613.405)
11. Count VI — Hate-Motivated Violence (NRS § 41.690)
12. Count VII — Parallel Federal Claim — 42 U.S.C. § 1981
13. Count VIII — Parallel Federal Claim — Title VII / ADA / ADEA
14. Damages
15. Prayer for Relief
16. Demand for Trial by Jury
17. Reservation of Rights
18. Signature and Service Blocks
19. Verification
20. Certificate of Service
21. Nevada Practice Notes
22. Sources and References

1. CAPTION

EIGHTH JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA

IN AND FOR THE COUNTY OF [________________________________]

CASE NO. [________________________________]

DEPT. NO. [________________________________]

COMPLAINT FOR DAMAGES, DECLARATORY RELIEF, AND INJUNCTIVE RELIEF

1. Discrimination in Violation of NRS § 613.330 (NEOA);
2. Hostile Work Environment / Harassment in Violation of NRS § 613.330;
3. Retaliation in Violation of NRS § 613.340;
4. Public Accommodations Discrimination in Violation of NRS § 651.070 and § 651.090;
5. Pregnancy Discrimination in Violation of NRS § 613.405;
6. Hate-Motivated Violence in Violation of NRS § 41.690;
7. Violation of 42 U.S.C. § 1981; and
8. Violation of [Title VII / ADA / ADEA].

EXEMPT FROM ARBITRATION — DAMAGES IN EXCESS OF $50,000

DEMAND FOR JURY TRIAL

Plaintiff, by and through counsel, complains and alleges as follows:

2. INTRODUCTION

2.1. This is a civil rights action arising from Defendants' unlawful discrimination, harassment, and retaliation against Plaintiff on the basis of [PROTECTED CHARACTERISTIC — e.g., race, color, religion, sex, sexual orientation, gender identity or expression, age, disability, national origin].

2.2. Plaintiff brings claims under the Nevada Equal Employment Opportunity Act ("NEOA"), NRS § 613.330 et seq.; Nevada's public-accommodations statute, NRS Chapter 651; Nevada's hate-violence civil-action statute, NRS § 41.690; and parallel federal civil rights laws.

2.3. Plaintiff seeks compensatory damages (economic and non-economic), punitive damages, declaratory and injunctive relief, and reasonable attorney fees and costs under NRS §§ 613.4353-613.4383, NRS § 651.090, NRS § 41.690, and 42 U.S.C. §§ 1988 and 2000e-5(k).

3. PARTIES, JURISDICTION, AND VENUE

3.1. Plaintiff. Plaintiff [PLAINTIFF NAME] ("Plaintiff") is, and at all relevant times has been, a resident of [CITY, COUNTY], Nevada. Plaintiff is a member of one or more classes protected by NRS § 613.330 and NRS § 651.070, including [PROTECTED CLASS(ES)].

3.2. Defendant Employer / Business. Defendant [DEFENDANT BUSINESS] ("Defendant" or "[SHORT NAME]") is, and at all relevant times has been, a [corporation / limited liability company / partnership / sole proprietorship] organized under the laws of [STATE], conducting business in [COUNTY], Nevada.

3.3. Defendant [BUSINESS] is an "employer" within the meaning of NRS § 613.310(2), having employed fifteen (15) or more persons for each working day in twenty (20) or more calendar weeks in the current or preceding calendar year.

3.4. Defendant [BUSINESS] is also a "place of public accommodation" within the meaning of NRS § 651.050.

3.5. Individual Defendant. Defendant [INDIVIDUAL DEFENDANT NAME] ("Individual Defendant") is, and at all relevant times was, a [supervisor / manager / agent] of Defendant [BUSINESS] acting within the course and scope of that agency.

3.6. Doe / Roe Defendants. Plaintiff is informed and believes, and based thereon alleges, that each of the Doe and Roe Defendants is responsible in some manner for the events and occurrences alleged herein. Plaintiff will seek leave to amend this Complaint to allege the true names and capacities of such Doe and Roe Defendants when ascertained.

3.7. Subject-matter jurisdiction. This Court has subject-matter jurisdiction over this action pursuant to Nev. Const. Art. 6, § 6 and NRS § 4.370 because the amount in controversy exceeds $15,000, exclusive of interest and costs, and the causes of action arise under Nevada and federal law.

3.8. Personal jurisdiction. Defendants are subject to the personal jurisdiction of this Court because they reside, do business, and committed the unlawful acts complained of within the State of Nevada.

3.9. Venue. Venue is proper in [COUNTY] County under NRS § 13.040 because the unlawful conduct occurred in this County and Defendants conduct business in this County.

4. ADMINISTRATIVE EXHAUSTION (NEOA COUNTS)

4.1. On or about [DATE], Plaintiff timely filed a charge of discrimination with the Nevada Equal Rights Commission ("NERC"), Charge No. [________________________________], alleging the unlawful conduct described herein.

4.2. Plaintiff's NERC charge was filed within three hundred (300) days of the last discriminatory act, as required by NRS § 233.160(1)(a)(2).

4.3. The NERC charge was cross-filed with the U.S. Equal Employment Opportunity Commission ("EEOC") under the work-sharing agreement between NERC and EEOC pursuant to 29 C.F.R. § 1601.13. EEOC Charge No. [________________________________].

4.4. On or about [DATE], NERC issued Plaintiff a right-to-sue notice pursuant to NRS § 613.420. A true and correct copy of the right-to-sue notice is attached hereto as Exhibit A.

4.5. [Where applicable] On or about [DATE], the EEOC issued Plaintiff a Notice of Right to Sue. A true and correct copy is attached hereto as Exhibit B.

4.6. This Complaint is filed within ninety (90) days of the issuance of the NERC right-to-sue notice as required by NRS § 613.420(2) and NRS § 613.430, and within ninety (90) days of receipt of any EEOC Notice of Right to Sue as required by 42 U.S.C. § 2000e-5(f)(1).

4.7. Plaintiff has thereby exhausted all administrative remedies as to the NEOA and federal employment counts.

5. COMMON FACTUAL ALLEGATIONS

5.1. Plaintiff began [employment with / patronage of / interaction with] Defendant on or about [DATE] as a [POSITION / CAPACITY].

5.2. At all relevant times, Plaintiff was qualified for, and performed competently in, [the position / the protected activity], meeting Defendant's legitimate expectations.

5.3. Plaintiff is a member of the following protected class(es) under Nevada law: [PROTECTED CLASS(ES) — e.g., race (Black/African American), national origin (Mexican), sex (female), disability (mobility impairment), religion (Muslim), sexual orientation (LGBTQ+), gender identity (transgender), age (40+)].

5.4. Beginning on or about [DATE], Plaintiff was subjected to the following adverse and discriminatory conduct:

• [SPECIFIC INCIDENT 1 — date, decision-maker, conduct, witnesses];
• [SPECIFIC INCIDENT 2];
• [SPECIFIC INCIDENT 3].

5.5. Plaintiff complained of the discriminatory conduct to [HR / SUPERVISOR / MANAGER] on [DATE(S)], but Defendant failed to take prompt and effective remedial action.

5.6. [Where applicable] Defendant denied Plaintiff full and equal goods, services, facilities, privileges, advantages, or accommodations on the basis of [protected class], in violation of NRS § 651.070.

5.7. [Where applicable] Defendant terminated, demoted, refused to hire, denied promotion to, or constructively discharged Plaintiff on [DATE].

5.8. Similarly situated [employees / patrons] outside Plaintiff's protected class(es) were not subjected to the same adverse treatment.

5.9. Defendant's stated reasons for the adverse action are pretextual, and the true motivation was discrimination based on Plaintiff's protected characteristic(s).

5.10. As a direct and proximate result, Plaintiff has suffered economic damages (lost wages, lost benefits, and lost earning capacity), non-economic damages (humiliation, emotional distress, anxiety, loss of dignity), and is entitled to compensatory damages, punitive damages, and attorney fees as set forth below.

6. COUNT I — NEOA DISCRIMINATION (NRS § 613.330)

6.1. Plaintiff incorporates Paragraphs 1 through 5.10 as though fully set forth.

6.2. At all relevant times, Defendant was an "employer" within the meaning of NRS § 613.310(2), having fifteen (15) or more employees for each working day in twenty (20) or more calendar weeks.

6.3. Plaintiff was an "employee" or "applicant" within the meaning of NEOA and a member of one or more protected classes under NRS § 613.330(1), which prohibits discrimination on the basis of race, color, religion, sex, sexual orientation, gender identity or expression, age, disability, or national origin.

6.4. Defendant subjected Plaintiff to adverse employment action, including [termination / failure to hire / failure to promote / demotion / pay disparity / denial of accommodation], because of Plaintiff's [PROTECTED CHARACTERISTIC].

6.5. Plaintiff's protected characteristic was a motivating factor in Defendant's adverse action under the framework adopted by Nevada courts. See Pope v. Motel 6, 121 Nev. 307, 114 P.3d 277 (2005) (applying McDonnell Douglas burden-shifting in Nevada employment discrimination cases).

6.6. As a direct and proximate result, Plaintiff has suffered and will continue to suffer economic and non-economic damages in amounts to be proven at trial.

6.7. Defendant's conduct was malicious, oppressive, and/or in conscious disregard of Plaintiff's rights, entitling Plaintiff to punitive damages under NRS § 42.005 and the expanded remedies provisions of NRS §§ 613.4353-613.4383.

6.8. Plaintiff is entitled to reasonable attorney fees and costs pursuant to NRS § 613.4377.

7. COUNT II — NEOA HOSTILE WORK ENVIRONMENT / HARASSMENT (NRS § 613.330)

7.1. Plaintiff incorporates Paragraphs 1 through 5.10 as though fully set forth.

7.2. Plaintiff was subjected to unwelcome conduct based on [PROTECTED CHARACTERISTIC] by Individual Defendant and/or other agents of Defendant, including [SPECIFIC HARASSING CONDUCT].

7.3. The harassment was sufficiently severe or pervasive to alter the conditions of Plaintiff's employment and to create an abusive working environment, evaluated under both an objective and subjective standard. See Pope v. Motel 6, 121 Nev. 307, 114 P.3d 277 (2005); Apeceche v. White Pine Cnty., 96 Nev. 723 (1980).

7.4. Defendant knew or should have known of the harassment and failed to take immediate and appropriate corrective action.

7.5. As a direct and proximate result, Plaintiff has suffered the damages described above.

8. COUNT III — NEOA RETALIATION (NRS § 613.340)

8.1. Plaintiff incorporates Paragraphs 1 through 5.10 as though fully set forth.

8.2. Plaintiff engaged in protected activity under NEOA by [opposing discrimination / filing an internal complaint / filing a NERC charge / requesting accommodation / participating in an investigation] on [DATE(S)].

8.3. NRS § 613.340(1) makes it unlawful for an employer to discriminate against any employee or applicant "because the employee or applicant has opposed any practice made an unlawful employment practice by NRS 613.310 to 613.435, inclusive, or because the employee or applicant has made a charge, testified, assisted or participated in any manner in an investigation, proceeding or hearing under those sections."

8.4. Defendant subjected Plaintiff to adverse employment action — namely [ADVERSE ACTION] — on [DATE], after and because of Plaintiff's protected activity.

8.5. A causal link exists between the protected activity and the adverse action, evidenced by [temporal proximity / direct admissions / pretext / shifting explanations].

8.6. As a direct and proximate result, Plaintiff has suffered the damages described above.

9. COUNT IV — PUBLIC ACCOMMODATIONS DISCRIMINATION (NRS § 651.070, § 651.090)

9.1. Plaintiff incorporates Paragraphs 1 through 5.10 as though fully set forth.

9.2. Defendant operates a "place of public accommodation" within the meaning of NRS § 651.050, including [restaurants, hotels, casinos, retail establishments, theaters, transportation facilities, and any other facility serving the public].

9.3. NRS § 651.070 entitles "all persons" to "the full and equal enjoyment of the goods, services, facilities, privileges, advantages and accommodations of any place of public accommodation, without discrimination or segregation on the ground of race, color, religion, national origin, disability, sexual orientation, sex, gender identity or expression."

9.4. Defendant denied Plaintiff full and equal enjoyment of its goods, services, facilities, privileges, advantages, or accommodations because of Plaintiff's [PROTECTED CHARACTERISTIC], in violation of NRS § 651.070.

9.5. Pursuant to NRS § 651.090, Plaintiff is entitled to bring a civil action for actual damages, equitable relief (including injunctive relief), and such other relief as the Court deems appropriate.

9.6. Public-accommodation claims under Chapter 651 do NOT require administrative exhaustion before NERC.

10. COUNT V — NEVADA PREGNANT WORKERS' FAIRNESS ACT (NRS § 613.405)

10.1. Plaintiff incorporates Paragraphs 1 through 5.10 as though fully set forth.

10.2. [Where applicable] Plaintiff was pregnant, recently gave birth, or experienced a related medical condition during the relevant period.

10.3. NRS § 613.405 prohibits employers with fifteen (15) or more employees from refusing to provide reasonable accommodations to female employees and applicants for conditions related to pregnancy, childbirth, or related medical conditions, absent undue hardship.

10.4. Defendant denied Plaintiff a reasonable accommodation for a pregnancy-related condition and/or subjected Plaintiff to adverse action because of pregnancy or pregnancy-related accommodation.

10.5. As a direct and proximate result, Plaintiff has suffered the damages described above.

11. COUNT VI — HATE-MOTIVATED VIOLENCE (NRS § 41.690)

11.1. Plaintiff incorporates Paragraphs 1 through 5.10 as though fully set forth.

11.2. [Where applicable] Defendants, by [describe physical injury / property damage / threats of force], intentionally selected Plaintiff as a victim, or selected Plaintiff's property as a target, in whole or in part because of Plaintiff's actual or perceived race, color, religion, national origin, physical or mental disability, sexual orientation, or gender identity or expression.

11.3. NRS § 41.690 provides a civil cause of action with statutory damages of not less than $5,000, plus actual damages, punitive damages, attorney fees, and costs.

11.4. Plaintiff is entitled to recover statutory damages, actual damages, punitive damages, attorney fees, and costs from Defendants.

12. COUNT VII — PARALLEL FEDERAL CLAIM — 42 U.S.C. § 1981

12.1. Plaintiff incorporates Paragraphs 1 through 5.10 as though fully set forth.

12.2. 42 U.S.C. § 1981 guarantees all persons within the United States the same right to make and enforce contracts as is enjoyed by white citizens.

12.3. Defendant interfered with Plaintiff's rights to make, perform, modify, and terminate contracts on the basis of race, in violation of § 1981.

12.4. Section 1981 does not require administrative exhaustion and provides a four-year statute of limitations under 28 U.S.C. § 1658 for post-formation contract claims.

12.5. Plaintiff is entitled to compensatory and punitive damages, attorney fees under 42 U.S.C. § 1988, and equitable relief.

13. COUNT VIII — PARALLEL FEDERAL CLAIM — TITLE VII / ADA / ADEA

13.1. Plaintiff incorporates Paragraphs 1 through 5.10 as though fully set forth.

13.2. [Where employment discrimination is alleged] Defendant violated Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e-2, by discriminating against Plaintiff in the terms, conditions, or privileges of employment on the basis of [race / color / religion / sex / national origin].

13.3. [Where disability discrimination is alleged] Defendant violated Title I of the ADA, 42 U.S.C. § 12112, by discriminating against, failing to accommodate, or retaliating against Plaintiff because of Plaintiff's disability or record of disability.

13.4. [Where age discrimination is alleged] Defendant violated the Age Discrimination in Employment Act, 29 U.S.C. § 623, by subjecting Plaintiff (age 40 or older) to adverse employment action because of age.

13.5. [Where public accommodation is alleged] Defendant violated Title II of the Civil Rights Act of 1964, 42 U.S.C. § 2000a, and/or Title III of the ADA, 42 U.S.C. § 12182.

13.6. Plaintiff timely filed a charge with the EEOC under the work-share agreement with NERC and received a Notice of Right to Sue.

13.7. Plaintiff is entitled to compensatory damages (subject to the Title VII statutory cap, 42 U.S.C. § 1981a(b)(3), where applicable), back pay, front pay, punitive damages, attorney fees under 42 U.S.C. § 2000e-5(k), and equitable relief.

14. DAMAGES

14.1. Economic damages: lost wages, lost benefits, lost earning capacity, lost employment opportunities, out-of-pocket expenses, and consequential pecuniary losses, in amounts to be proven at trial.

14.2. Non-economic damages: emotional distress, mental anguish, humiliation, loss of dignity, anxiety, embarrassment, and loss of enjoyment of life, in amounts to be proven at trial.

14.3. Statutory damages — Hate-Motivated Violence (NRS § 41.690): Not less than $5,000 plus actual damages.

14.4. Punitive damages: Pursuant to NRS § 42.005, NRS § 613.4377, and 42 U.S.C. § 1981a, Defendants' conduct was malicious, oppressive, or in conscious disregard of Plaintiff's rights, warranting punitive damages in amounts sufficient to punish and deter.

14.5. Attorney fees and costs: Recoverable under NRS § 613.4377, NRS § 651.090, NRS § 41.690, NRS § 18.010, 42 U.S.C. § 1988, and 42 U.S.C. § 2000e-5(k).

14.6. Pre-judgment and post-judgment interest as allowed by NRS § 17.130 and applicable federal law.

15. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully prays for judgment against Defendants, jointly and severally, as follows:

• A. For compensatory damages (economic and non-economic) according to proof, in excess of $15,000, exclusive of interest and costs;
• B. For statutory damages of not less than $5,000 under NRS § 41.690 (where applicable);
• C. For punitive and exemplary damages under NRS § 42.005, NRS § 613.4377, and 42 U.S.C. § 1981a;
• D. For declaratory judgment that Defendants' conduct violated Nevada and federal civil rights laws;
• E. For injunctive relief, including reinstatement, accommodation, training, policy reform, and posting of notices;
• F. For pre-judgment and post-judgment interest at the maximum legal rate;
• G. For reasonable attorney fees and costs under all applicable fee-shifting statutes;
• H. For such other and further relief the Court deems just and proper.

16. DEMAND FOR TRIAL BY JURY

Plaintiff hereby demands a trial by jury on all issues so triable as a matter of right pursuant to Nev. R. Civ. P. 38, the Nevada Constitution Art. 1, § 3, and the Seventh Amendment to the United States Constitution.

17. RESERVATION OF RIGHTS

Plaintiff reserves the right to amend this Complaint pursuant to Nev. R. Civ. P. 15 to identify Doe and Roe Defendants, to add additional claims revealed in discovery, and to conform the pleadings to proof at trial.

18. SIGNATURE AND SERVICE BLOCKS

Date: [DATE]

Respectfully submitted,

[LAW FIRM NAME]

By: [________________________________]

[ATTORNEY NAME], Nev. State Bar No. [######]

Counsel for Plaintiff

[STREET ADDRESS]

[CITY, STATE ZIP]

Telephone: [NUMBER]

Email: [EMAIL]

19. VERIFICATION

STATE OF NEVADA

COUNTY OF [________________________________]

I, [PLAINTIFF NAME], being first duly sworn, depose and say that I am the Plaintiff in the foregoing action; that I have read the foregoing Complaint and know the contents thereof; and that the same is true of my own knowledge except as to those matters stated upon information and belief, and as to those matters, I believe them to be true.

[________________________________]

[PLAINTIFF NAME]

Subscribed and sworn to before me this [____] day of [_______________], 20[____].

[________________________________]

Notary Public

(My Commission Expires: [_______________])

20. CERTIFICATE OF SERVICE

I hereby certify that on [DATE], I caused a true and correct copy of the foregoing COMPLAINT FOR DAMAGES, DECLARATORY RELIEF, AND INJUNCTIVE RELIEF to be served on the following parties by [method — personal service / mail / electronic service per Nev. R. Civ. P. 5(b) and the Eighth Judicial District Court Electronic Filing and Conversion Rules]:

[SERVICE LIST WITH ADDRESSES]

[________________________________]

[NAME / TITLE]

21. NEVADA PRACTICE NOTES

• Pleading standard. Nevada follows notice pleading under Nev. R. Civ. P. 8(a). Complaints must allege facts sufficient to give fair notice of the claim and its grounds. Conclusory allegations are vulnerable to dismissal under Nev. R. Civ. P. 12(b)(5). See Hay v. Hay, 100 Nev. 196 (1984).
• NEOA employer threshold (15 employees). NRS § 613.310(2) defines "employer" as a person with 15 or more employees for each working day in 20 or more calendar weeks in the current or preceding calendar year — matching Title VII's threshold. Smaller employers fall outside NEOA but may be reached through public accommodations (NRS 651.070) or § 1981 (race contracts).
• Sexual orientation and gender identity protections (2011). Nevada amended NRS § 613.330 in 2011 to add "sexual orientation" and "gender identity or expression" as protected classes, well before Bostock v. Clayton County, 590 U.S. 644 (2020). State-law protection is therefore independent of, and not preempted by, Title VII.
• Administrative exhaustion — 300 days. NRS § 233.160(1)(a)(2) requires NEOA charges to be filed with NERC within 300 days of the last discriminatory act. This matches the federal deferral-state EEOC window. Public-accommodation charges are also subject to the 300-day deadline; housing charges have a 1-year deadline (NRS 233.160(1)(b)).
• 180-day / 90-day litigation window. NRS § 613.430 imposes a 180-day limitation from the date of the act OR 90 days from the date of receipt of a NERC right-to-sue notice — whichever is later. The 180-day clock is tolled during NERC's pendency. After the right-to-sue notice issues, the 90-day clock is hard.
• Expanded remedies — Title VII parity (2019/2023). NRS §§ 613.4353-613.4383 extended Title VII-parity remedies (compensatory and punitive damages tiered by employer size; longer back-pay periods; attorney fees) to NEOA claims. Plead these expressly in the prayer for relief.
• Public accommodations — direct civil action. NRS § 651.090 authorizes a private civil action for actual damages and equitable relief without NERC exhaustion. NRS § 651.070's protected classes track Title II of the Civil Rights Act and the ADA Title III but include sexual orientation and gender identity or expression.
• Hate-motivated violence — NRS § 41.690. Provides a freestanding civil cause of action with $5,000 statutory minimum damages where bias-motivated physical injury, property damage, or threats of force occurred. Independent of underlying criminal conviction.
• Punitive damages. Generally capped under NRS § 42.005 at three times compensatory damages where compensatory damages are $100,000 or more, or $300,000 where less. Caps are inapplicable in certain product-liability and bad-faith cases.
• No FEHA-style $4,000 statutory floor. Unlike California's Unruh Act, Nevada's public-accommodations statute (NRS § 651.090) requires proof of actual damages plus equitable relief; no minimum statutory damages apply (contra NRS § 41.690's $5,000 floor for hate-motivated violence).
• Individual liability. Nevada courts follow the federal pattern — supervisors are not personally liable under NEOA absent participation in actionable harassment. Consider individual liability under NRS § 41.690, common-law tort theories, or aiding-and-abetting frameworks.
• Removal exposure. Adding federal counts (Title VII, § 1981, ADA, ADEA) creates federal-question jurisdiction permitting removal under 28 U.S.C. § 1441. Strategic choice: plead state counts only to anchor in Nevada district court, or include federal counts to access § 1988 fees.
• Statutes of limitation summary.
• NEOA (NRS 613.330): 180 days from act / 90 days post-RTS, whichever is later (NRS 613.430).
• Public accommodations (NRS 651.090): 2-year personal-injury limit (NRS 11.190(4)(e)) generally applies absent more specific provision.
• Hate-motivated violence (NRS 41.690): 2 years (NRS 11.190(4)(e)).
• § 1981 (post-formation contract): 4 years (28 U.S.C. § 1658).
• § 1983: 2 years (borrowed from Nevada personal-injury limit).
• Title VII: 90 days after EEOC right-to-sue notice.
• Exhaustion is jurisdictional only as to NEOA counts. Allum v. Valley Bank, 109 Nev. 280 (1993). Failure to exhaust is fatal to NEOA but does not bar parallel non-NEOA state claims.
• District court vs. justice court. Civil actions exceeding $15,000 must be filed in district court (NRS § 4.370). Civil rights actions almost always exceed this threshold.

22. SOURCES AND REFERENCES

• NRS Chapter 613 (Employment Practices) — https://www.leg.state.nv.us/NRS/NRS-613.html
• NRS § 613.310 (definitions; 15-employee threshold) — https://www.leg.state.nv.us/NRS/NRS-613.html#NRS613Sec310
• NRS § 613.330 (NEOA — unlawful employment practices) — https://www.leg.state.nv.us/NRS/NRS-613.html#NRS613Sec330
• NRS § 613.340 (retaliation) — https://www.leg.state.nv.us/NRS/NRS-613.html#NRS613Sec340
• NRS § 613.405 (Nevada Pregnant Workers' Fairness Act)
• NRS § 613.420 (right-to-sue notice; 90-day filing window) — https://www.leg.state.nv.us/NRS/NRS-613.html#NRS613Sec420
• NRS § 613.430 (limitation on actions: 180/90 days) — https://www.leg.state.nv.us/NRS/NRS-613.html#NRS613Sec430
• NRS §§ 613.4353-613.4383 (Title VII parity remedies)
• NRS Chapter 233 (Nevada Equal Rights Commission) — https://www.leg.state.nv.us/nrs/nrs-233.html
• NRS § 233.020 (definitions) — https://www.leg.state.nv.us/nrs/nrs-233.html#NRS233Sec020
• NRS § 233.150 (NERC powers and duties)
• NRS § 233.160 (administrative complaint deadlines: 300 days / 1 year) — https://www.leg.state.nv.us/nrs/nrs-233.html#NRS233Sec160
• NRS Chapter 651 (Public Accommodations) — https://www.leg.state.nv.us/NRS/NRS-651.html
• NRS § 651.070 (equal enjoyment) — https://www.leg.state.nv.us/NRS/NRS-651.html#NRS651Sec070
• NRS § 651.090 (private civil action)
• NRS § 41.690 (hate-motivated violence civil action)
• NRS § 42.005 (punitive damages caps)
• Nevada Equal Rights Commission — https://detr.nv.gov/Page/Nevada_Equal_Rights_Commission
• NERC Public Complaint Portal — https://mynerccomplaint.nv.gov/
• Pope v. Motel 6, 121 Nev. 307, 114 P.3d 277 (2005) (McDonnell Douglas framework in Nevada)
• Apeceche v. White Pine Cnty., 96 Nev. 723 (1980) (hostile work environment)
• Allum v. Valley Bank, 109 Nev. 280 (1993) (exhaustion under NEOA)
• Pope v. Motel 6, 121 Nev. 307 (2005)
• 42 U.S.C. § 1981, § 1983, § 1988 — https://www.eeoc.gov/statutes
• 42 U.S.C. § 2000a, § 2000e-2 — https://www.eeoc.gov/statutes/title-vii-civil-rights-act-1964
• 42 U.S.C. § 12112, § 12182 (ADA) — https://www.ada.gov/
• 29 U.S.C. § 621 et seq. (ADEA) — https://www.eeoc.gov/age-discrimination
• 29 C.F.R. § 1601.13 (EEOC-state work-share) — https://www.ecfr.gov/

Disclaimer: This template is provided for informational purposes only and does not constitute legal advice. An attorney licensed in Nevada must review and customize this document before filing. Laws, citations, and court rules change frequently; verify all authorities before use.