What is the current state of the law on continuing violations in employment law?

We next consider whether Bird's claim qualifies as a continuing violation. The continuing violations doctrine functions as an exception to the discovery rule of accrual "allowing a plaintiff to seek relief for events outside of the limitations period." Knox, 260 F.3d at 1013. Although the continuing violations doctrine is most frequently seen in the context of employment discrimination suits, we have held that the continuing violations doctrine also applies to 1983 claims. See id. ("The continuing violation theory applies to 1983 actions."); Cherosky v. Henderson, 330 F.3d 1243,

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