Morris v. Frank IX & Sons, Inc
In Morris v. Frank IX & Sons, Inc. (W.D.Va. 1980) 486 F. Supp. 728, 732-733, the court stated, "an employer's failure to recall or rehire an individual after a layoff does not constitute a continuing violation of the Age Discrimination in Employment Act."
Rather, "each alleged discriminatory recall constitutes a separate and completed act by the defendant, which triggers a new limitations period." (Ibid.)