Richards

A jury awarded $1.4 million to plaintiff Lachi Richards against her former employer, defendant CH2M Hill, Inc., for disability discrimination in violation of the Fair Employment and Housing Act (FEHA or Act) (Gov.Code, § 12900 et seq.). Most of the acts of discrimination upon which her claims were based, however, occurred outside of the one-year statute of limitations set forth in the Act, which requires that an employee file an administrative complaint within "one year from the date upon which the alleged unlawful [employment] practice .... occurred, except that this period may be extended ... for not to exceed 90 days ... if a person allegedly aggrieved ... first obtained knowledge of the facts of the alleged unlawful practice after the expiration of one year from the date of their occurrence...." (Gov.Code, § 12960.) The trial court ruled that the "continuing violation" doctrine permitted plaintiff to assert all of her claims arising over a five-year period.

We conclude that a series of claims that an employee knowingly permits to expire cannot be revived by characterizing them singularly as a "continuing violation" once a new claim arises within the limitations…