Continuing Violation of Harassment Extends Statute of Limitations for 1983 Claim

Over the course a decade, Panagiota Heath alleges she suffered continual harassment from her supervisor Mostafa Elaasar. Both Heath and Mostafa worked in the math department at Southern University’s New Orleans campus. When Heath filed a charge with the EEOC in 2013, the Magistrate Judge hearing the case ruled in favor of the University because most of the harassing conduct occurred outside the statute of limitations for her Title VII claim and her 1983 claim. The Fifth Circuit reversed the District Court decision and remanded for additional proceedings to determine whether there had been harassment that led to a hostile work environment for Heath from the time she returned from a leave of absence in 2011 until her claim was filed. Find out the case law referenced and why the Title VII claim was not reversed here.