an unfair practice under ICRA and providing treble damages for willful violations of workers’ rights); 2009 Iowa Acts ch. 178, §§ 25-27 (reducing paperwork in ICRA proceedings); see also 1991 Iowa Acts ch. 184 (empowering the commission to award relief for discrimination in housing, creating a private cause of action in district court for housing discrimination, and permitting an award of actual and punitive damages for instances of housing discrimination). 3 . Some states have statutes dealing with employment discrimination that do not create a private cause of action in district court. See, e.g., Ga.Code Ann. §§ 45-19-38 to -39, (West 2003) (providing for resolution of complaints by a special master with an opportunity to appeal to a district court); N.C. Gen.Stat. § 143-422.2 (2001) (<HOLDING>); S.C.Code Ann. §§ 1-13-90, -100 (2005)
recognizing a public policy against discrimination but not providing for an independent cause of action recognizing the cause of action recognizing cause of action by class member against class counsel for negligence in providing notice recognizing cause of action recognizing that defendant could raise recoupment defense against state but not independent cause of action or counterclaim