continuing violation in Rhode Island

2009See Provencher v. CVS Pharmacy, Division of Melville Corporation , 145 F.3d 5 , 13-14 (1st Cir. 1998) ("A continuing violation allows a plaintiff not only to allege otherwise time-barred acts, but more concretely, to receive damages, such as back pay, based on and reaching back to those acts.") To assert a claim under the continuing violation doctrine, a "complaint must indicate that not only the injury, but the discrimination, is in fact on-going." Goldman v. Sears, Roebuck Co. , 607 F.2d 1014 , 1018 (1st Cir. 1979); Velazquez v. Chardon , 576 F.Supp. 476 , 477 (D.

2005See Goldman v. Sears, Roebuck & Co., 607 F.2d 1014, 1018 (1st Cir.1979) (“A continuing violation is not stated if all that appears from the complaint is that the plaintiff continues to suffer from the ongoing effects of some past act of discrimination.”); see also Gilbert v. City of Cambridge, 932 F.2d 51, 58-59 (1st Cir.1991) (distinguishing “between a continuing act and a singular act that brings continuing consequences in its roiled wake.”); Altair Corp. v. Pesquera de Busquets, 769 F.2d 30, 32 (1st Cir.1985) (“[Plaintiffs] argument concerning the continuing violation exception to the gener

2019See id. ; see also Asociación de Suscripción Conjunta del Seguro de Responsabilidad Obligatorio v. Juarbe-Jiménez , 659 F.3d 42 , 51 (1st Cir. 2011) ("Even under [the continuing violation] doctrine, the 'ongoing injuries' or harmful 'effects' of a single unlawful act do not extend the limitations period.") (quoting Jensen v. Frank , 912 F.2d 517 , 523 (1st Cir. 1990) ); Carpenter v. Texaco, Inc. , 419 Mass. 581 , 646 N.E.2d 398 , 399 (1995) ("[A] continuing trespass or nuisance must be based on recurring tortious or unlawful conduct and is not established by the continuation of harm caused by

2005See Goldman v. Sears, Roebuck & Co., 607 F.2d 1014, 1018 (1st Cir.1979) (“A continuing violation is not stated if all that appears from the complaint is that the plaintiff continues to suffer from the ongoing effects of some past act of discrimination.”); see also Gilbert v. City of Cambridge, 932 F.2d 51, 58-59 (1st Cir.1991) (distinguishing “between a continuing act and a singular act that brings continuing consequences in its roiled wake.”); Altair Corp. v. Pesquera de Busquets, 769 F.2d 30, 32 (1st Cir.1985) (“[Plaintiffs] argument concerning the continuing violation exception to the gener

2026“Generally, ‘a cause of action accrues and the applicable statute of limitations begins to run at the time of the injury to the aggrieved party.’” Boudreau v. Automatic Temperature Controls, Inc., 212 A.3d 594, 600 (R.I. 2019) (quoting American States Insurance Company v. LaFlam, 69 A.3d 831, 840 (R.I. 2013)).

2026“Generally, ‘a cause of action accrues and the applicable statute of limitations begins to run at the time of the injury to the aggrieved party.’” Boudreau v. Automatic Temperature Controls, Inc., 212 A.3d 594, 600 (R.I. 2019) (quoting American States Insurance Company v. LaFlam, 69 A.3d 831, 840 (R.I. 2013)).

2019See id. ; see also Asociación de Suscripción Conjunta del Seguro de Responsabilidad Obligatorio v. Juarbe-Jiménez , 659 F.3d 42 , 51 (1st Cir. 2011) ("Even under [the continuing violation] doctrine, the 'ongoing injuries' or harmful 'effects' of a single unlawful act do not extend the limitations period.") (quoting Jensen v. Frank , 912 F.2d 517 , 523 (1st Cir. 1990) ); Carpenter v. Texaco, Inc. , 419 Mass. 581 , 646 N.E.2d 398 , 399 (1995) ("[A] continuing trespass or nuisance must be based on recurring tortious or unlawful conduct and is not established by the continuation of harm caused by

2019See id. ; see also Asociación de Suscripción Conjunta del Seguro de Responsabilidad Obligatorio v. Juarbe-Jiménez , 659 F.3d 42 , 51 (1st Cir. 2011) ("Even under [the continuing violation] doctrine, the 'ongoing injuries' or harmful 'effects' of a single unlawful act do not extend the limitations period.") (quoting Jensen v. Frank , 912 F.2d 517 , 523 (1st Cir. 1990) ); Carpenter v. Texaco, Inc. , 419 Mass. 581 , 646 N.E.2d 398 , 399 (1995) ("[A] continuing trespass or nuisance must be based on recurring tortious or unlawful conduct and is not established by the continuation of harm caused by

2019Moreover, in line with caselaw from the First Circuit Court of Appeals, we have declined to apply the continuing violation doctrine to an age discrimination case when the underlying act was "a discrete act" and held that any alleged claims of discrimination after that act did not toll the running of the statute of limitations, but were merely continuing consequences of that single act. 9 Croce v. State, Office of Adjutant General , 881 A.2d 75 , 79 (R.I. 2005) ; see also Quality Cleaning Products R.C., Inc. v. SCA Tissue North America, LLC , 794 F.3d 200 , 206 (1st Cir. 2015) ("Courts have lar

2019The plaintiff appealed, alleging that the continuing violation doctrine tolled the statute of limitations because there was "a pattern of continuing discriminatory acts and that at least one of those discriminatory acts occurred within [the] statute of limitations period." Id. at 78 .

2019See id. ; see also Asociación de Suscripción Conjunta del Seguro de Responsabilidad Obligatorio v. Juarbe-Jiménez , 659 F.3d 42 , 51 (1st Cir. 2011) ("Even under [the continuing violation] doctrine, the 'ongoing injuries' or harmful 'effects' of a single unlawful act do not extend the limitations period.") (quoting Jensen v. Frank , 912 F.2d 517 , 523 (1st Cir. 1990) ); Carpenter v. Texaco, Inc. , 419 Mass. 581 , 646 N.E.2d 398 , 399 (1995) ("[A] continuing trespass or nuisance must be based on recurring tortious or unlawful conduct and is not established by the continuation of harm caused by

2019Moreover, in line with caselaw from the First Circuit Court of Appeals, we have declined to apply the continuing violation doctrine to an age discrimination case when the underlying act was "a discrete act" and held that any alleged claims of discrimination after that act did not toll the running of the statute of limitations, but were merely continuing consequences of that single act. 9 Croce v. State, Office of Adjutant General , 881 A.2d 75 , 79 (R.I. 2005) ; see also Quality Cleaning Products R.C., Inc. v. SCA Tissue North America, LLC , 794 F.3d 200 , 206 (1st Cir. 2015) ("Courts have lar

2009See Provencher v. CVS Pharmacy, Division of Melville Corporation , 145 F.3d 5 , 13-14 (1st Cir. 1998) ("A continuing violation allows a plaintiff not only to allege otherwise time-barred acts, but more concretely, to receive damages, such as back pay, based on and reaching back to those acts.") To assert a claim under the continuing violation doctrine, a "complaint must indicate that not only the injury, but the discrimination, is in fact on-going." Goldman v. Sears, Roebuck Co. , 607 F.2d 1014 , 1018 (1st Cir. 1979); Velazquez v. Chardon , 576 F.Supp. 476 , 477 (D.

2009See Provencher v. CVS Pharmacy, Division of Melville Corporation , 145 F.3d 5 , 13-14 (1st Cir. 1998) ("A continuing violation allows a plaintiff not only to allege otherwise time-barred acts, but more concretely, to receive damages, such as back pay, based on and reaching back to those acts.") To assert a claim under the continuing violation doctrine, a "complaint must indicate that not only the injury, but the discrimination, is in fact on-going." Goldman v. Sears, Roebuck Co. , 607 F.2d 1014 , 1018 (1st Cir. 1979); Velazquez v. Chardon , 576 F.Supp. 476 , 477 (D.

2005See Goldman v. Sears, Roebuck & Co., 607 F.2d 1014, 1018 (1st Cir.1979) (“A continuing violation is not stated if all that appears from the complaint is that the plaintiff continues to suffer from the ongoing effects of some past act of discrimination.”); see also Gilbert v. City of Cambridge, 932 F.2d 51, 58-59 (1st Cir.1991) (distinguishing “between a continuing act and a singular act that brings continuing consequences in its roiled wake.”); Altair Corp. v. Pesquera de Busquets, 769 F.2d 30, 32 (1st Cir.1985) (“[Plaintiffs] argument concerning the continuing violation exception to the gener

2005See Goldman v. Sears, Roebuck & Co., 607 F.2d 1014, 1018 (1st Cir.1979) (“A continuing violation is not stated if all that appears from the complaint is that the plaintiff continues to suffer from the ongoing effects of some past act of discrimination.”); see also Gilbert v. City of Cambridge, 932 F.2d 51, 58-59 (1st Cir.1991) (distinguishing “between a continuing act and a singular act that brings continuing consequences in its roiled wake.”); Altair Corp. v. Pesquera de Busquets, 769 F.2d 30, 32 (1st Cir.1985) (“[Plaintiffs] argument concerning the continuing violation exception to the gener

2005See Goldman v. Sears, Roebuck & Co., 607 F.2d 1014, 1018 (1st Cir.1979) (“A continuing violation is not stated if all that appears from the complaint is that the plaintiff continues to suffer from the ongoing effects of some past act of discrimination.”); see also Gilbert v. City of Cambridge, 932 F.2d 51, 58-59 (1st Cir.1991) (distinguishing “between a continuing act and a singular act that brings continuing consequences in its roiled wake.”); Altair Corp. v. Pesquera de Busquets, 769 F.2d 30, 32 (1st Cir.1985) (“[Plaintiffs] argument concerning the continuing violation exception to the gener

2005See Goldman v. Sears, Roebuck & Co., 607 F.2d 1014, 1018 (1st Cir.1979) (“A continuing violation is not stated if all that appears from the complaint is that the plaintiff continues to suffer from the ongoing effects of some past act of discrimination.”); see also Gilbert v. City of Cambridge, 932 F.2d 51, 58-59 (1st Cir.1991) (distinguishing “between a continuing act and a singular act that brings continuing consequences in its roiled wake.”); Altair Corp. v. Pesquera de Busquets, 769 F.2d 30, 32 (1st Cir.1985) (“[Plaintiffs] argument concerning the continuing violation exception to the gener

2005See Goldman v. Sears, Roebuck & Co., 607 F.2d 1014, 1018 (1st Cir.1979) (“A continuing violation is not stated if all that appears from the complaint is that the plaintiff continues to suffer from the ongoing effects of some past act of discrimination.”); see also Gilbert v. City of Cambridge, 932 F.2d 51, 58-59 (1st Cir.1991) (distinguishing “between a continuing act and a singular act that brings continuing consequences in its roiled wake.”); Altair Corp. v. Pesquera de Busquets, 769 F.2d 30, 32 (1st Cir.1985) (“[Plaintiffs] argument concerning the continuing violation exception to the gener

2005See Goldman v. Sears, Roebuck & Co., 607 F.2d 1014, 1018 (1st Cir.1979) (“A continuing violation is not stated if all that appears from the complaint is that the plaintiff continues to suffer from the ongoing effects of some past act of discrimination.”); see also Gilbert v. City of Cambridge, 932 F.2d 51, 58-59 (1st Cir.1991) (distinguishing “between a continuing act and a singular act that brings continuing consequences in its roiled wake.”); Altair Corp. v. Pesquera de Busquets, 769 F.2d 30, 32 (1st Cir.1985) (“[Plaintiffs] argument concerning the continuing violation exception to the gener

2005See Goldman v. Sears, Roebuck & Co., 607 F.2d 1014, 1018 (1st Cir.1979) (“A continuing violation is not stated if all that appears from the complaint is that the plaintiff continues to suffer from the ongoing effects of some past act of discrimination.”); see also Gilbert v. City of Cambridge, 932 F.2d 51, 58-59 (1st Cir.1991) (distinguishing “between a continuing act and a singular act that brings continuing consequences in its roiled wake.”); Altair Corp. v. Pesquera de Busquets, 769 F.2d 30, 32 (1st Cir.1985) (“[Plaintiffs] argument concerning the continuing violation exception to the gener

2005See Goldman v. Sears, Roebuck & Co., 607 F.2d 1014, 1018 (1st Cir.1979) (“A continuing violation is not stated if all that appears from the complaint is that the plaintiff continues to suffer from the ongoing effects of some past act of discrimination.”); see also Gilbert v. City of Cambridge, 932 F.2d 51, 58-59 (1st Cir.1991) (distinguishing “between a continuing act and a singular act that brings continuing consequences in its roiled wake.”); Altair Corp. v. Pesquera de Busquets, 769 F.2d 30, 32 (1st Cir.1985) (“[Plaintiffs] argument concerning the continuing violation exception to the gener

2005See Goldman v. Sears, Roebuck & Co., 607 F.2d 1014, 1018 (1st Cir.1979) (“A continuing violation is not stated if all that appears from the complaint is that the plaintiff continues to suffer from the ongoing effects of some past act of discrimination.”); see also Gilbert v. City of Cambridge, 932 F.2d 51, 58-59 (1st Cir.1991) (distinguishing “between a continuing act and a singular act that brings continuing consequences in its roiled wake.”); Altair Corp. v. Pesquera de Busquets, 769 F.2d 30, 32 (1st Cir.1985) (“[Plaintiffs] argument concerning the continuing violation exception to the gener

2005See Goldman v. Sears, Roebuck & Co., 607 F.2d 1014, 1018 (1st Cir.1979) (“A continuing violation is not stated if all that appears from the complaint is that the plaintiff continues to suffer from the ongoing effects of some past act of discrimination.”); see also Gilbert v. City of Cambridge, 932 F.2d 51, 58-59 (1st Cir.1991) (distinguishing “between a continuing act and a singular act that brings continuing consequences in its roiled wake.”); Altair Corp. v. Pesquera de Busquets, 769 F.2d 30, 32 (1st Cir.1985) (“[Plaintiffs] argument concerning the continuing violation exception to the gener

2005See Goldman v. Sears, Roebuck & Co., 607 F.2d 1014, 1018 (1st Cir.1979) (“A continuing violation is not stated if all that appears from the complaint is that the plaintiff continues to suffer from the ongoing effects of some past act of discrimination.”); see also Gilbert v. City of Cambridge, 932 F.2d 51, 58-59 (1st Cir.1991) (distinguishing “between a continuing act and a singular act that brings continuing consequences in its roiled wake.”); Altair Corp. v. Pesquera de Busquets, 769 F.2d 30, 32 (1st Cir.1985) (“[Plaintiffs] argument concerning the continuing violation exception to the gener

2005See Goldman v. Sears, Roebuck & Co., 607 F.2d 1014, 1018 (1st Cir.1979) (“A continuing violation is not stated if all that appears from the complaint is that the plaintiff continues to suffer from the ongoing effects of some past act of discrimination.”); see also Gilbert v. City of Cambridge, 932 F.2d 51, 58-59 (1st Cir.1991) (distinguishing “between a continuing act and a singular act that brings continuing consequences in its roiled wake.”); Altair Corp. v. Pesquera de Busquets, 769 F.2d 30, 32 (1st Cir.1985) (“[Plaintiffs] argument concerning the continuing violation exception to the gener