Abram-Adams v. Citigroup, Inc.

Patricia Abram-Adams, proceeding pro se, appeals the district court’s sua sponte dismissal of her complaint against her former employer, Citigroup, Inc. (Citigroup). The district court dismissed the complaint as untimely and therefore frivolous under 28 U.S.C. § 1915(e)(2)(B). At issue on appeal is whether Abram-Adams’s complaint was timely. After reviewing the record and briefs, we affirm.

I. Background

This appeal is best understood within the context of its winding procedural history. Abram-Adams’s claims arise from: (1) her employment with Citigroup in 2003-04; and (2) an arbitrator’s…