A former Citigroup employee can’t pursue a retaliation claim under the Sarbanes-Oxley Act because he waited too long to file a Department of Labor complaint, the Third Circuit ruled Wednesday.

The appeals court affirmed the dismissal after determining that it had jurisdiction. The Sarbanes-Oxley statute of limitations—and the act’s requirement that plaintiffs exhaust their administrative remedies through an agency process—"prescribe the route that parties must take to the courthouse doors but do not lock those doors,” Judge Stephanos Bibas said.

The US Court of Appeals for the Third Circuit is splitting from the Second Circuit in its approach to the ...

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