110, 114, 122 S.Ct. 2061. The Supreme Court contrasted discrete acts of discrimination with hostile work environment claims, for which the continuing violation doctrine remained available, because hostile work environment claims by “[t]heir very nature involve[] repeated conduct,” and further explained that “a single act of harassment may not be actionable on its own.” Id. at 115, 122 S.Ct. 2061. Although Morgan discussed the continuing violation doctrine in the context of Title VII, many courts have held that an alleged failure to provide a requested accommodation under the Rehabilitation Act or the ADA is also a “discrete act” under Morgan and thus cannot rest on a continuing violation theory to make it timely. See, e.g., Cherosky v. Henderson, 330 F.3d 1243, 1246-47 (9th Cir.2003) (<HOLDING>); Szedlock v. Tenet, 61 Fed.Appx. 88, 93 (4th
holding that the same standards apply to claims under the ada and under the rehabilitation act holding that denials of hearingimpaired employees multiple requests for accommodations under the rehabilitation act were each discrete acts of discrimination under morgan holding rehabilitation act applicable holding that denial of request for accommodation of religion is a discrete act under morgan holding that denial of employees request for respirators under the rehabilitation act was a discrete act of discrimination under morgan