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United States First Circuit

Ayala v. Shinseki, 13-2260

In this case, plaintiff filed a civil action pursuant to Title VII's anti-retaliation provision (24 U.S.C. section 2000e-3(a)) against defendant Department of Veterans Affairs, her former employer. The district court ruled that plaintiff's Title VII retaliation claims were time-barred and entered partial summary judgment in favor of defendant. The judgment is affirmed, where, since both employment actions challenged by plaintiff constitute discrete acts, the continuing violation doctrine does not apply to plaintiff's claims, and thus her claims are time-barred.

Appellate Information

  • Decided 03/06/2015
  • Published 03/06/2015


  • Torruella


  • United States First Circuit


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