practice ‘occurs’ for purposes of Title VII’s timing provisions and holding that “[a] discrete retaliatory or discriminatory act ‘occurred’ on the day that it ‘happened.’ ”). In Stewart v. Ashcroft, 352 F.3d 422 (D.C.Cir. 2003), the court of appeals held that an allegedly discriminatory non-promotion occurs on the date that the selected applicant assumes her or his new position. Id. at 425. In Stewart, the plaintiff initiated EEO procedures on August 12, 1998, while the promoted employee assumed his new role on February 3, 1998 — well over 100 days earlier. Id. Because the promotion became effective on February 3, 1998, the court of appeals deemed the complaint untimely. Id.; see also Armstrong v. Jackson, Civil Action No. 05-75(JDB), 2006 WL 2024975 at =‘4 (D.D.C. July 17, 2006) (<HOLDING>). Here, Davis’ hiring became effective March
holding that the date of the federal indictment not the date of the state arrest was the triggering date for the speedytrial act holding that the commission on remand can set the effective date of a rate to be the effective date of the original commission activity holding that the date on which the plaintiff learned of the defendants denial of tenure not the date on which the plaintiff became unemployed was when the statute of limitations began to run holding that limitations period on employment discrimination claim triggered on date of discharge not on date of discovery of discriminatory intent holding that the date of discrimination is the date on which a decision not to hire a plaintiff becomes effective