Holding that a knowing plaintiff has an obligation to file promptly or lose his claim as "distinguished from a plaintiff who is unable to appreciate that he is being discriminated against until he has lived through a series of acts and is thereby able to perceive the overall discriminatory pattern."
In Miller v. Shawmut Bank of Boston, 726 F. Supp. 337 (D.Mass. 1989), the court determined that a promotion to personal banker from customer services representative was sufficient to save a ยง 1981 claim from summary judgment, particularly when internal company memos showed that the jobs were considerably different.
Holding that three denied promotions over the course of three years, where the decisions were made by three different selection officials and involved different qualifications were not sufficiently related to constitute a continuing violation