entitled to a “continuing violation” instruction — that is, that the jury could conclude that, as long as one act fell within the limitations period (i.e., after July 9, 1999), other related acts that took place outside the limitations period were actionable as part of a continuing violation. See Pl.’s Mem. 7-9; Pl.’s Reply at 8-10. In response, defendant argues that the Supreme Court in National Railroad Passenger Corp. v. Morgan, 536 U.S. 101, 122 S.Ct. 2061, 153 L.Ed.2d 106 (2002), foreclosed application of the “continuing violation” doctrine in c 1343 (D.Kan.2006) (reasoning that, under Morgan, “rejection of an employee’s proposed accommodation is a discrete act” that begins the ADA limitations period); Lipka v. Potter, No. 03CV381A, 2006 WL 839421, at *4 (W.D.N.Y. Mar.28, 2006) (<HOLDING>); see also Elmenayer v. ABF Freight Sys., 318
recognizing hostile work environment discrimination in ada context holding that claim for reasonable accommodation under the ada was timebarred the continuing violation doctrine applies only to cases of alleged hostile work environment or other claims which involve a series of acts necessary to comprise the alleged discriminatory act recognizing a hostile work environment claim under section 1983 holding that a viable hostile work environment claim requires an environment that a reasonable person would find hostile or abusive recognizing that the elements of title vii sexually hostile work environment claims apply to icra sexually hostile work environment claims