The Seventh Circuit held yesterday that it lacked jurisdiction to review an order remanding a case to state court — despite the plaintiff’s failure to join and serve an in-state defendant at the time of removal. The court deemed the order unreviewable because it constituted a remand for lack of jurisdiction within 28 U.S.C. 1447(c). Holmstrom v. Peterson , No. 05-3670 (7th Cir. July 3, 2007) (citing Powerex Corp. v. Reliant Energy Svcs.., No. 05-85 (June 18, 2007) (available at

Barry Barnett