Williams v. New York City Housing Authority

In Williams v. New York City Housing Authority, 61 A.D.3d 62 (1st Dep't 2009) the First Department approved of the post-National Railroad Passenger Corp. viability of the "continuing violation" rule, as applied to claims arising in New York City and alleging discrete discriminatory acts. The First Department found that, unlike the more restrictive federal law, "the Restoration Act's uniquely remedial provisions are consistent with a rule that neither penalizes workers who hesitate to bring an action at the first sign of what they suspect could be discriminatory trouble nor rewards covered entities that discriminate by insulating them from challenges to their unlawful conduct that continues into the limitations period." (Williams, 61 A.D.3d at 72-73.)