Justice Erika M. Edwards
Employee Shizari sued defendants alleging discrimination based on, among other things, religion and disability. Defendants moved for dismissal arguing the majority of Shirazi’s discriminatory conduct claims were time-barred. Shirazi alleged the claims were timely as the continuing violation doctrine and hostile work environment were all part of a pattern of discrimination over several years. She alleged the discrimination was due to a disability she developed from stress of her personal and professional responsibilities. She claimed defendants denied her reasonable requests for accommodation of her disabilities, and retaliated by denying her requests for a leave of absence, among other things. The court granted dismissal of Shirazi’s disability discrimination claims concerning rejection of her reasonable requests for accommodation as they were barred by the three-year statute of limitations, and she failed to link such allegations to a continuing pattern of discrimination. Yet, dismissal was denied for discrimination based on religion, race, national origin and retaliation under the state and city Human Rights Laws as Shirazi sufficiently pleaded the claims were part of a continuing violation and long-term pattern of discrimination extending past the three-year limitations period.