one of its board members wrote to Driscoll to complain about the removal. See Comp. ¶ 28. Therefore, because this case was filed in 2005, six years later, ATAA’s claims are barred by the three-year statute of limitations. Contrary to the ATAA’s contention, this case does not involve an alleged continuing violation of constitutional rights that extends the statute of limitations. Chairman Peyser’s 2005 letter to plaintiffs’ attorney reiterating the board’s explanation for the 1999 removal of the contra-genocide websites from the Curriculum Guide was essentially a refusal to remedy the effects of an alleged earlier constitutional violation and, therefore is not independently actionable as part of a serial violation. See, e.g., De Leon Otero v. Rubero, 820 F.2d 18, 20 (1st Cir.l987)(<HOLDING>). Similarly, the ATAA has identified no ongoing
holding in the discrimination context that a plaintiff may challenge incidents which occurred outside the statute of limitations period if the various acts of discrimination constitute a continuing pattern of discrimination holding in an employment discrimination case that later refusals to reinstate the plaintiff did not create a continuing violation but were a consequence of his initial demotion holding in an employment discrimination case that the continued employment of the plaintiffs rival in a position previously held by the plaintiff did not constitute a systemic violation holding that an employer in an employment discrimination case may not justify its conduct based on evidence that did not motivate it at the time of the employment decision holding in title vii case that plaintiff demonstrated adverse employment action in school districts decision not to renew principals contract for the following year but offering principal a demotion