Sharon Andersen v. Department of Health and Human Services

Summary

The court affirmed summary judgment for the Department because Andersen did not make a prima facie showing that any event within the limitations period was part of a continuing disability-based hostile-work-environment violation. The Department's refusal to reassign her was not itself evidence of a continuing violation, and her resignation more than seven months after leaving work was too disconnected to constitute a constructive discharge. The court therefore did not reach the substantive validity of her discrimination claim.