A S1983 discriminatory treatment claim accrues for purposes of the statute of limitation when the plaintiff is aware of the adverse decision and capable of seeking injunctive or declaratory relief.
http://media.ca8.uscourts.gov/opndir/18/06/171265P.pdf
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.