context: In addition, courts have consistently treated the failure to promote as a discrete act; one that is more in the nature of an isolated employment decision than a persistent pattern.
citation_a.signal: see also
citation_a.identifier: 110 F.3d 907, 907
citation_a.parenthetical: finding that alleged demotions and denials of pay-grade increases were completed acts not continuing in nature
citation_a.sentence: Pauling v. Secretary of the Interior, 960 F.Supp. 793, 801-02 (S.D.N.Y.1997) (“Demotion, failure to promote, and termination have all been deemed discrete acts); Samuel v. Merrill Lynch Pierce Fenner & Smith, 771 F.Supp. 47, 49 (S.D.N.Y.1991) (“As decided by several courts in this Circuit, a number of incidents of failure to promote cannot, as a matter of law, constitute a ‘series of related acts.’ ”); see also Lightfoot, 110 F.3d at 907 (finding that alleged demotions and denials of pay-grade increases were completed acts not continuing in nature); but see Williams v. Chase Manhattan Bank, N.A., 728 F.Supp. 1004, 1007 (S.D.N.Y.1990) (stating that “since [plaintiff] alleges a series of related discriminatory events including several denials of the same promotion, her complaint is deemed one of continuing violations”).
citation_b.signal: but see
citation_b.identifier: 728 F.Supp. 1004, 1007
citation_b.parenthetical: stating that "since [plaintiff] alleges a series of related discriminatory events including several denials of the same promotion, her complaint is deemed one of continuing violations"
citation_b.sentence: Pauling v. Secretary of the Interior, 960 F.Supp. 793, 801-02 (S.D.N.Y.1997) (“Demotion, failure to promote, and termination have all been deemed discrete acts); Samuel v. Merrill Lynch Pierce Fenner & Smith, 771 F.Supp. 47, 49 (S.D.N.Y.1991) (“As decided by several courts in this Circuit, a number of incidents of failure to promote cannot, as a matter of law, constitute a ‘series of related acts.’ ”); see also Lightfoot, 110 F.3d at 907 (finding that alleged demotions and denials of pay-grade increases were completed acts not continuing in nature); but see Williams v. Chase Manhattan Bank, N.A., 728 F.Supp. 1004, 1007 (S.D.N.Y.1990) (stating that “since [plaintiff] alleges a series of related discriminatory events including several denials of the same promotion, her complaint is deemed one of continuing violations”).