Havens Realty Corp. v. Coleman

In Havens Realty Corp. v. Coleman (1982), 455 U.S. 363, 380-381, 102 S. Ct. 1114, 71 L. Ed. 2d 214, even though four of the five racial steering incidents occurred outside the FHA statute of limitations, the Supreme Court found all five incidents timely under the continuing violation theory, because the violation that occurred within the statute of limitations was manifested in the number of incidents that occurred outside the statute of limitations. Id. at 380. Requiring that at least one of the forbidden discriminatory acts occurs within the relevant limitations period ensures the limitation period begins to run in response to discriminatory acts themselves, not in response to the continuing effects of past discrimination. Deck, at 893; Moseke v. Miller (E.D.Vir. 2002), 202 F. Supp. 2d 492, 506; United Air Lines v. Evans (1977), 431 U.S. 553, 557, 97 S. Ct. 1885, 52 L. Ed. 2d 571; Delaware State College v. Ricks (1980), 449 U.S. 250, 258, 101 S. Ct. 498, 66 L. Ed. 2d 431.