Originally published by David Coale.
1. Improper joinder when the acts of the nondiverse employee that allegedly tortiously interfered with the plaintiff’s contract were ratified by the employer. Denson v. Beavex, Inc., No. 14-20534 (May 22, 2015, unpublished).
2. No appellate jurisdiction when the district court administratively closed the case in favor of arbitration. “[A]n order by the district court administratively closing a case is tantamount to a stay, and bars appellate review.” Walker v. TA Operating, LLC, No. 14-41046 (May 22, 2015, unpublished).
3. “[A] district court cannot permissively abstain from exercising jurisdiction in proceedings related to Chapter 15 [cross-border bankruptcy] cases.” Firefighters’ Retirement System v. Citco Group Ltd., No. 14-30857 (June 5, 2015).
4. A lawyer who intervenes in a client’s case to protect a fee interest must independently establish diversity of citizenship and the requisite amount in controversy. Samuels v. Twin City, No. 14-31203 (May 18, 2015, unpublished).
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