Poore v. Am.-Amicable Life Ins. Co. of Texas, 218 F.3d 1287 (11th Cir. 2000). · Go Syfert
Poore v. Am.-Amicable Life Ins. Co. of Texas, 218 F.3d 1287 (11th Cir. 2000). Cases Citing This Book View Copy Cite
112 citation events (111 in the last 25 years) across 22 distinct courts.
Strongest positive: Lawrence Lee, Jr. and Michelle Sparks v. James Roth (alsd, 2026-01-06)
Treatment trajectory · 2000 → 2026 · click a year to view as-of
2000 2013 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
discussed Cited as authority (verbatim quote) Lawrence Lee, Jr. and Michelle Sparks v. James Roth
S.D. Ala. · 2026 · quote attribution · 1 verbatim quote · confidence high
vents occurring after removal . . . do not oust the district court's jurisdiction.
discussed Cited as authority (verbatim quote) Pugh v. International Paper Company
S.D. Ala. · 2024 · quote attribution · 1 verbatim quote · confidence high
vents occurring after removal . . . do not oust the district court's jurisdiction.
discussed Cited as authority (verbatim quote) Bargmann v. State Farm Mutual Automobile Insurance Company
S.D. Ala. · 2024 · quote attribution · 1 verbatim quote · confidence high
vents occurring after removal . . . do not oust the district court's jurisdiction.
discussed Cited as authority (verbatim quote) Jackson v. Constellation Brands, Inc.
S.D. Ala. · 2023 · quote attribution · 1 verbatim quote · confidence high
vents occurring after removal . . . do not oust the district court's jurisdiction.
discussed Cited as authority (verbatim quote) Heathcoe v. Patriot Timber Products, Inc.
S.D. Ala. · 2023 · quote attribution · 1 verbatim quote · confidence high
vents occurring after removal . . . do not oust the district court's jurisdiction.
discussed Cited as authority (verbatim quote) Reese v. WestRock CP, LLC (2×) also: Cited as authority (rule)
S.D. Ala. · 2022 · quote attribution · 1 verbatim quote · confidence high
vents occurring after removal . . . do not oust the district court's jurisdiction.
discussed Cited as authority (verbatim quote) Gamble v. Allstate Insurance Company
S.D. Ala. · 2021 · quote attribution · 1 verbatim quote · confidence high
events occurring after removal . . . do not oust the district court's jurisdiction.
discussed Cited as authority (verbatim quote) Southern Tank Leasing, Inc. v. K & M Express, Inc.
S.D. Ala. · 2019 · quote attribution · 1 verbatim quote · confidence high
events occurring after removal which may reduce the damages recoverable below the amount in controversy requirement do not oust the district court's jurisdiction
discussed Cited as authority (verbatim quote) PTA-FLA, Inc. v. ZTE USA, Inc.
11th Cir. · 2016 · quote attribution · 1 verbatim quote · confidence high
vents occurring after removal which may reduce the damages recoverable below the amount in controversy requirement do not oust the district court's jurisdiction.
discussed Cited as authority (quoted) Stacy v. Reliance Standard Life Insurance Company
S.D. Ala. · 2022 · quote attribution · 1 verbatim quote · confidence low
vents occurring after removal . . . do not oust the district court's jurisdiction.
discussed Cited as authority (quoted) State of Oklahoma v. Ascension Healthcare (2×) also: Cited as authority (rule)
N.D. Okla. · 2021 · quote attribution · 1 verbatim quote · confidence low
he district court must determine whether it had subject matter jurisdiction at the time of removal.
discussed Cited as authority (quoted) Masingill v. ServisFirst Bancshares, Inc.
S.D. Ala. · 2021 · quote attribution · 1 verbatim quote · confidence low
events occurring after removal . . . do not oust the district court's jurisdiction.
discussed Cited as authority (quoted) Barefield v. HSBC Holdings PLC
E.D. Cal. · 2018 · quote attribution · 1 verbatim quote · confidence low
vents occurring after removal which may reduce the damages recoverable below the amount in controversy requirement do not oust the district court's jurisdiction.
cited Cited as authority (rule) Eduardo Cuesta v. Holiday CVS, LLC d/b/a CVS Pharmacy Y Mas (Store #3706)
S.D. Fla. · 2026 · confidence medium
Co., 218 F.3d 1287, 1290-91 (11th Cir. 2000).
cited Cited as authority (rule) Mark Dawson v. American Economy Insurance Company
M.D. Ala. · 2026 · confidence medium
Co. of Texas, 218 F.3d 1287, 1290-91 (11th Cir. 2000), overruled on other grounds by Alvarez v. Uniroyal Tire Co., 508 F.3d 639 (11th Cir. 2007).
cited Cited as authority (rule) Thomas Tucker and Amber Tucker v. Ally Financial Inc. and FCA US, LLC
M.D. Ala. · 2025 · confidence medium
Co. of Texas, 218 F.3d 1287, 1290-91 (11th Cir. 2000), overruled on other grounds by Alvarez v. Uniroyal Tire Co., 508 F.3d 639 (11th Cir. 2007).
cited Cited as authority (rule) Diseree Hoffman v. Alabama CVS Pharmacy L.L.C.
M.D. Ala. · 2025 · confidence medium
Co. of Texas, 218 F.3d 1287, 1290-91 (11th Cir. 2000), overruled on other grounds by Alvarez v. Uniroyal Tire Co., 508 F.3d 639, 640-41 (11th Cir. 2007).
discussed Cited as authority (rule) Grubbs v. Lowe's Home Centers, LLC (CONSENT)
M.D. Ala. · 2025 · confidence medium
With this rule in mind, the court in Miller found “the [p]laintiff’s stipulation regarding the amount in controversy is an example of an ‘event[] occurring after removal.’” Id. (quoting Poore, 218 F.3d at 1291) (second alteration in original).
cited Cited as authority (rule) Smitherman v. Cloudtrucks, LLC
S.D. Ala. · 2025 · confidence medium
Co. of Texas, 218 F.3d 1287, 1291 (11th Cir. 2000), overruled in part on other grounds in Alvarez v. Uniroyal Tire Co., 508 F.3d 639, 641 (11th Cir.2007).
discussed Cited as authority (rule) Huddleston v. American Modern Property and Casualty Insurance Company (CONSENT)
M.D. Ala. · 2023 · confidence medium
Co. of Texas, 218 F.3d 1287, 1290-91 (11h Cir. 2000) (overruled on other grounds by Alvarez v. Uniroyal Tire Co., 508 F.3d 639, 640-41 (11th Cir. 2007)).
cited Cited as authority (rule) Rodriguez v. Evanston Insurance Company
S.D. Fla. · 2021 · confidence medium
Co. of Tex., 218 F.3d 1287, 1291 (11th Cir. 2000), overruled on other grounds, Alvarez v. Uniroyal Tire Co., 508 F.3d 639 (11th Cir. 2007) (per curiam).
cited Cited as authority (rule) Castillo v. GEOVERA SPECIALTY INSURANCE COMPANY
S.D. Fla. · 2021 · confidence medium
Co. of Tex., 218 F.3d 1287, 1290-91 (11th Cir. 2000)), overruled on other grounds by Alvarez v. Uniroyal Tire Co., 508 F.3d 639, 640 (11th Cir. 2007)).
cited Cited as authority (rule) Marambio v. Scottsdale Insurance Company
S.D. Fla. · 2020 · confidence medium
Co. of Tex., 218 F.3d 1287, 1290-91 (11th Cir. 2000))).
cited Cited as authority (rule) Caceres v. Scottsdale Insurance Company
S.D. Fla. · 2019 · confidence medium
Co. of Tex., 218 F.3d 1287, 1290-91 (11th Cir. 2000))).
cited Cited as authority (rule) Oliva v. GeoVera Specialty Insurance Company
S.D. Fla. · 2019 · confidence medium
Co. of Texas, 218 F.3d 1287, 1290-91 (11th Cir. 2000))).
cited Cited as authority (rule) Pate v. Baldwin County Alabama
S.D. Ala. · 2019 · confidence medium
Co. of Texas, 218 F.3d 1287, 1290-1291 (11th Cir. 2000)).
discussed Cited as authority (rule) Batchelor v. American Optical Corp.
S.D. Fla. · 2016 · confidence medium
Co. of Tx., 218 F.3d 1287, 1291 (11th Cir.2000), overruled in part on other grounds in Alvarez v. Uniroyal Tire Co., 508 F.3d 639, 640-41 (11th Cir.2007); Ehlen Floor Covering, Inc. v. Lamb, 660 F.3d 1283, 1287 (11th Cir.2011) (“The existence of federal jurisdiction is tested as of the time of removal.”).
discussed Cited as authority (rule) Exum v. State Farm Fire & Casualty Co.
M.D. Ala. · 2011 · confidence medium
Co. of Tx., 218 F.3d at 1287, 1290-91 (11th Cir.2000), overruled on other grounds by Alvarez v. Uniroyal Tire Co., 508 F.3d 639, 641 (11th Cir.2007); see also Leonard v. Enterprise Rent A Car, 279 F.3d 967, 972 (11th Cir. *1295 2002) (“If jurisdiction was proper at that date [the date of removal], subsequent events, even the loss of the required amount in controversy, will not operate to divest the court of jurisdiction.”).
cited Cited as authority (rule) Lee-Bolton v. Koppers Inc.
N.D. Fla. · 2011 · confidence medium
Co. of Texas, 218 F.3d 1287, 1290-91 (11th Cir.2000); Lake County v. NRG/Recovery Group, Inc., 144 F.Supp.2d 1316, 1319 (M.D.Fla.2001).
cited Cited as authority (rule) Fulmer v. LEISURE BAY INDUSTRIES, INC.
N.D. Ala. · 2011 · confidence medium
Co. of Tex., 218 F.3d 1287, 1291 (11th Cir.2000) (overruled on other grounds by Alvarez v. Uniroyal Tire Co., 508 F.3d 639 (11th Cir.2007)).
examined Cited as authority (rule) Nelson v. Whirlpool Corp. (3×)
S.D. Ala. · 2010 · confidence medium
Thus, “events occurring after removal which may reduce the damages recoverable below the amount in controversy requirement do not oust the district court’s jurisdiction.” Poore, 218 F.3d at 1291.
cited Cited as authority (rule) Jacqueline M. Eparvier v. Fortis Insurance Company
11th Cir. · 2008 · confidence medium
Co. of Texas, 218 F.3d 1287, 1289 (11th Cir.2000), abrogated on other grounds by Alvarez v. Uniroyal Tire Co., 508 F.3d 639 (11th Cir.2007).
discussed Cited as authority (rule) Price v. J & H Marsh & McLennan, Inc. (2×) also: Cited "see, e.g."
2d Cir. · 2007 · confidence medium
See, e.g., Reddam v. KPMG LLP, 457 F.3d 1054, 1058-59 (9th Cir.2006) (upholding appellate jurisdiction over remand order based on determination that arbitrator’s post-removal refusal to arbitrate deprived the court of subject matter jurisdiction); Poore v. American-Amicable Life Insurance Co. of Texas, 218 F.3d 1287, 1291-92 (11th Cir.2000) (upholding appellate jurisdiction over remand order based on post-removal event reducing damages recoverable below the amount-in-controversy requirement); In re Amoco Petroleum Additives Co., 964 F.2d 706, 708-09 (7th Cir.1992) (upholding appellate jurisd…
cited Cited as authority (rule) Palmer v. Local 8285 United Steel Workers of America
11th Cir. · 2007 · confidence medium
Co. of Tex., 218 F.3d 1287, 1289-91 (11th Cir.2000).
discussed Cited as authority (rule) Purple Passion, Inc. v. RCN Telecom Services, Inc.
S.D.N.Y. · 2005 · confidence medium
Co. of Texas, 218 F.3d 1287, 1290-91 (11th Cir.2000) (joining “every Circuit that has addressed this issue” and holding that “events occurring after removal which may reduce the damages recoverable below the amount in controversy requirement do not oust the district court’s jurisdiction”); Hudson United Bank v. LiTenda Mortgage Corp., 142 F.3d 151 , 157 n. 8 (3d Cir.1998) (“Congress did not mean to upset [the focus on jurisdiction at the time of removal] and that [the traditional rule] remainfs] in effect unchanged by the intervening textual modifications to § 1447(c).”); Doddy …
cited Cited as authority (rule) Merced-Torres v. Merck & Co., Inc.
M.D. Fla. · 2005 · confidence medium
Co. of Tex., 218 F.3d 1287, 1291 (11th Cir.2000).
cited Cited as authority (rule) H.T. Hackney Co. v. REWJB Gas Investments (In Re United Petroleum Group, Inc.)
Bankr. S.D. Florida · 2004 · confidence medium
Co. of Texas, 218 F.3d 1287, 1290-1291 (11th Cir.2000).
cited Cited as authority (rule) Yusefzadeh v. Nelson, Mullins, Riley & Scarborough, LLP
11th Cir. · 2004 · confidence medium
Co. of Texas, 218 F.3d 1287, 1289 (11th Cir.2000).
examined Cited as authority (rule) Clark Construction Group, Inc. v. Hellmuth, Obata & Kassabaum, Inc. (3×) also: Cited "see"
M.D. Fla. · 2003 · confidence medium
Co. of Tex., 218 F.3d 1287, 1290-91 (11th Cir.2000). *1350 III.
cited Cited as authority (rule) Schuster v. Gardner
S.D. Cal. · 2003 · confidence medium
Co. of Texas, 218 F.3d 1287, 1290-91 (11th Cir.2000)).
cited Cited as authority (rule) Egan v. Premier Scales & Systems
W.D. Ky. · 2002 · confidence medium
Co. of Texas, 218 F.3d 1287, 1290 (11th Cir.2000); In re Shell Oil Company, 966 F.2d 1130, 1133 (7th Cir.1992).
discussed Cited as authority (rule) Charles H. Behlen v. Merrill Lynch
11th Cir. · 2002 · confidence medium
In Poore v. Americana-Amicable Life Insurance Co. of Texas, 218 F.3d 1287, 1290-91 (11th Cir.2000), we joined our sister circuits in holding that if a district court has subject matter jurisdiction over a diversity action at the time of removal, subsequent acts do not divest the court of its jurisdiction over the action.
cited Cited as authority (rule) American Dental Industries, Inc. v. Eax Worldwide, Inc.
D. Or. · 2002 · confidence medium
Co. of Texas, 218 F.3d 1287, 1290 (11th Cir.2000); In re Shell Oil Company, 966 F.2d 1130, 1133 (7th Cir.1992).
discussed Cited as authority (rule) Shannon Leonard v. Enterprise Rent A Car (2×) also: Cited "see"
11th Cir. · 2002 · confidence medium
Co. of Tex., 218 F.3d 1287, 1289-91 (11th Cir.2000).
discussed Cited as authority (rule) Lake County v. NRG/Recovery Group, Inc.
M.D. Fla. · 2001 · confidence medium
Paul Mercury Indemnity Co. v. Red Cab Co., 303 U.S. 283, 293 , 58 S.Ct. 586 , 82 L.Ed. 845 (1938)(”events occurring subsequent to removal which reduce the amount recoverable... do not oust the district court's jurisdiction once it has attached.”); Poore v. American-Amicable Life Insurance Co. of Texas, 218 F.3d 1287, 1290 (11th Cir.2000)("the district court must determine whether it had subject matter jurisdiction at the time of removal.”) 3 .
cited Cited as authority (rule) Lindsay v. American General Life & Accident Insurance
N.D. Ala. · 2001 · confidence medium
Co. of Texas, 218 F.3d 1287, 1291 (11th Cir.2000); Sierminski, 216 F.3d at 947.
cited Cited as authority (rule) Poore v. American-Amicable Life Insurance Co. of Texas
S.D. Ga. · 2000 · confidence medium
Co. of Tex., 218 F.3d 1287, 1292 (11th Cir.2000).
cited Cited "see" Philip Morris Inc v. Repub Venezuela
D.C. Cir. · 2002 · signal: see · confidence high
See Poore, 218 F.3d at 1289; Liberty Mut. v. Ward Trucking, 48 F.3d 742, 745-46 (3d Cir. 1995).
discussed Cited "see" Republic of Venezuela v. Philip Morris Incorporated (2×)
D.C. Cir. · 2002 · signal: see · confidence high
See Poore, 218 F.3d at 1289; Liberty Mut. v. Ward Trucking, 48 F.3d 742, 745-46 (3d Cir.1995).
Retrieving the full opinion text from the archive…
Michael POORE, Bruce Bias, Individually and on Behalf of All Others Similarly Situated, Plaintiffs-Appellees,
v.
AMERICAN-AMICABLE LIFE INSURANCE COMPANY OF TEXAS, Defendant-Appellant
99-12705.
Court of Appeals for the Eleventh Circuit.
Jul 20, 2000.
218 F.3d 1287
Thomas W. Tucker, Dye, Tucker, Ever-itt, Long & Brewton, P.A., Augusta, GA, Lewis E. Hassett, Morris, Manning & Martin, Atlanta, GA, Sharon Mollman Elliott, Roberta F. Howell, Gordon Davenport III, Foley & Lardner, Madison, WI, for Defendanb-Appellant., John E. Suthers, Savannah, GA, Billy N. Jones, Jones, Osteen, Jones & Arnold, Hinesville, GA, Paul J. Doolittle, Charleston, SC, Ron Parry and David A. Baker, Arnzen, Parry & Wentz, P.S.C., Covington, KY, for Plaintiffs-Appellees.
Anderson, Black, Hall.
Cited by 46 opinions  |  Published
5 passages pin-cited by 5 cases
Pinpoint authority: #26,566 of 633,719
Citer courts: S.D. Alabama (2) · E.D. California (1) · M.D. Florida (1) · N.D. Oklahoma (1)
BLACK, Circuit Judge:

Appellant American-Amicable Life Insurance Company of Texas appeals the district court’s order remanding the case filed by Appellees Michael Poore and Bruce Bias to state court pursuant to 28 U.S.C. § 1447(c). Appellant claims the district court did not have the authority to remand the case based on Appellees’ post-removal amended complaint. We agree. Accordingly, we reverse the district court’s order and remand with instructions.

[*1289] I. BACKGROUND

Appellees filed a class action complaint on October 19, 1998, in the Superior Court of Liberty County, Georgia. On behalf of a nationwide class of persons who purchased life insurance policies from Appellant, Appellees sought compensatory and punitive damages, recission, restitution, and injunctive relief against Appellant for alleged fraudulent life insurance policies. Appellees asserted that the relief sought would amount to less than $75,000 per class member.

On November 12,1998, Appellant filed a Notice of Removal to the United States District Court for the Southern District of Georgia alleging diversity jurisdiction, pursuant to 28 U.S.C. § 1332, as the basis for removal. Appellant claimed the amount in controversy requirement was met by aggregating the punitive damages sought in the complaint.

On November 25, 1998, Appellees filed a motion for leave to amend their complaint. The amended complaint deleted the claims for punitive damages and injunctive relief, and redefined the class to exclude any individual plaintiffs “who wish to assert punitive damages claims ... [or] claims where the matter in controversy exceeds ... $75,000.... ” The district court granted the motion to amend on December 7, 1998.

Subsequently, on December 15, 1998, Appellees filed a Motion to Remand, claiming the district court lacked subject matter jurisdiction. On July 21, 1999, pursuant to 28 U.S.C. § 1447(c), the district court remanded the case to the state court, finding that the amended complaint did not satisfy the amount in controversy requirement.

On appeal, Appellant claims the district court erred in relying on the amended complaint to determine whether the court had subject matter jurisdiction. We find the district court did so err, and therefore reverse and remand for the district court to determine whether the amount in controversy was met at the time of removal.

II. ANALYSIS

We review de novo a district court’s decision to remand based on 28 U.S.C. § 1447(c). See United States v. Veal, 153 F.3d 1233, 1245 (11th Cir.1998). A district court’s order pursuant to § 1447(c) is only renewable if the case is remanded on “grounds wholly different from those upon which § 1447(c) permits remand.” Thermtron Prods., Inc. v. Hermansdorfer, 423 U.S. 336, 346, 96 S.Ct. 584, 589, 46 L.Ed.2d 542 (1976); see 28 U.S.C. § 1447(d). In this case, the review-ability and merits of the order are inextricably intertwined. As discussed below, we conclude the district court’s order is reviewable and that the district court erred in granting the order. For ease of discussion, we first will discuss the district court’s error.

A. District Court’s Authority to Remand

Pursuant to 28 U.S.C. § 1447(c), a district court may remand cases when the court lacks subject matter jurisdiction. As originally enacted, § 1447(c) stated “[i]f at any time before final judgment it appears that the case was removed improvidently and without jurisdiction, the district court shall remand the case.... ” In analyzing this version of § 1447(c), courts made clear that removal was the critical jurisdictional juncture. See St. Paul Mercury Indem. Co. v. Red Cab Co., 303 U.S. 283, 293, 58 S.Ct. 586, 592, 82 L.Ed. 845 (1938) (stating “events occurring subsequent to removal which reduce the amount recoverable ... do not oust the district court’s jurisdiction”). That is, under the original version of § 1447(c), the proper inquiry was whether the court had jurisdiction at the time of removal. If the court did have jurisdiction at the time of removal, that jurisdiction was unaffected by subsequent acts, such as loss of diversity or loss of the required amount in controversy. See Freeport-McMoRan, Inc. v. KN Energy, Inc., 498 U.S. 426, 428, 111 S.Ct. 858, 860, 112 L.Ed.2d 951 (1991) (noting the Supreme Court has “consistently held that if jurisdiction exists at the time an action is[*1290] commenced, such jurisdiction may not be divested by subsequent events”); St. Paul Mercury Indemnity, 303 U.S. at 293, 58 S.Ct. at 592; Doddy v. Oxy USA, Inc., 101 F.3d 448, 456 n. 4 (5th Cir.1996) (explaining that a district court’s jurisdiction is fixed at the time of removal); Van Meter v. State Farm, Fire & Cas. Co., 1 F.3d 445, 450 (6th Cir.1993) (same).

Section 1447(c), however, was amended in 1988 to read as follows: “If at any time before final judgment it appears that the district court lacks subject matter jurisdiction, the case shall be remanded.” The district court concluded § 1447(c), as amended, authorized it to look at post-removal events to determine whether it had subject matter jurisdiction. On appeal, Appellant argues the district court’s interpretation of § 1447(c) was -incorrect and contends the amended statute still prohibits courts from relying on post-removal events in examining subject matter jurisdiction. We agree.

While the district court concluded the amended § 1447(c) suggests that the time of removal is no longer the focus of the inquiry, “courts have not construed it in this revolutionary way.” Baldridge v. Kentucky-Ohio Trans., Inc., 983 F.2d 1341, 1348 n. 11 (6th Cir.1993). Rather, every Circuit that has addressed this issue has held that the proper inquiry is still whether the court had jurisdiction at the time of removal. [1] For example, the Sixth Circuit has held that “the timing question is dispositive because, despite the change in the wording of § 1447(c) ... courts still read that section as authorizing remand when a district court determines that jurisdiction had been lacking at the time of removal, rather than later.... ” Baldridge, 983 F.2d at 1348. See Matter of Shell Oil Co., 966 F.2d 1130, 1133 (7th Cir.1992) (stating that “[njeither the text of the revised § 1447(c) nor its legislative history implies that Congress altered the traditional view ... that jurisdiction present at the time a suit is filed or removed is unaffected by subsequent acts”); Hudson United Bank v. Litenda Mortgage Corp., 142 F.3d 151, 157 n. 8 (3d Cir.1998) (commenting “we will assume Congress did not mean to upset [the focus on jurisdiction at the time of removal] and that they remain in effect unchanged by the intervening textual modifications to § 1447(c)”); Doddy, 101 F.3d at 456 n. 4 (5th Cir.1996) (explaining that “ § 1447(c) cannot be read to overrule the repeatedly expressed view that changes after removal cannot eliminate jurisdiction and require remand”); see also Wisconsin Dep’t of Corrections v. Schacht, 524 U.S. 381, 391, 118 S.Ct. 2047, 2053, 141 L.Ed.2d 364 (1998) (in discussing a different issue, noting that “[a] case such as this one is more closely analogous to cases, in which a later event, say the change in the citizenship of a party or a subsequent reduction of the amount at issue below jurisdictional levels, destroys previously existing jurisdiction. In such cases, a federal court will keep a removed case.”); Freeport-McMoRan, 498 U.S. at 428, 111 S.Ct. at 860 (in dicta, commenting that jurisdiction is fixed at the time of removal).

Finally, as noted by several other Circuits, the legislative history of § 1447(c) does not indicate that Congress intended the amendment to cause a drastic change in the law. See H.R.Rep. No. 104-799 at 2-3 (1996), U.S. Code Cong. & Admin. News at 3417, 3418-3419 (indicating that § 1447(c), as amended, was intended only to clarify Congressional intent with respect to the timeliness of remands made for reasons other than lack of subject matter jurisdiction); Hudson United Bank, 142 F.3d at 156 n. 8 (noting “Congress did not mean to upset” the established interpretation of § 1447(c)).

We join our sister Circuits and conclude the amendments to § 1447(c) did not alter the fact that, in this case, the district court must determine whether it[*1291] had subject matter jurisdiction at the time of removal. [2] That is, events occurring after removal which may reduce the damages recoverable below the amount in controversy requirement do .not oust the district court’s jurisdiction. In this case, Appellees amended their complaint after the case was removed to the district court. The district court thus erred in relying on the amended complaint to conclude the parties did not meet the amount in controversy requirement.

B. Reviewability of District Court’s Remand Order

Under 28 U.S.C. § 1447(d), an order remanding an action to state court pursuant to § 1447(c) is not reviewable on appeal or otherwise, even if the remand order is clearly erroneous. [3] See Thermtron Prods., Inc. v. Hermansdorfer, 423 U.S. 336, 342-43, 96 S.Ct. 584, 589, 46 L.Ed.2d 542 (1976). The Supreme Court, however, has explained that § 1447(d)’s bar to appellate review is not as broad as it seems. See id. at 345-46, 96 S.Ct. at 590; Matter of Amoco Petroleum Additives Co., 964 F.2d 706, 708 (7th Cir.1992) (noting § 1447(d) “does not mean what it says”). In Thermtron, the district court had remanded a diversity suit due to the crowded federal docket. Relying on the § 1447(d) bar, the Sixth Circuit refused to consider the defendant’s mandamus petition. The Supreme Court reversed, holding that § 1447(d) precludes review only of those remand orders issued pursuant to § 1447(c). See id. at 346, 96 S.Ct. at' 590 (stating “only remand orders issued under section 1447(c) and invoking the grounds specified therein — that removal was improvident and without jurisdiction — are immune from review under section 1447(d)”). Because the district court had not remanded on the basis of § 1447(c), but rather on “grounds wholly different from those upon which Section 1447(c) permits remand,” the district court had exceeded its authority and the remand order was thus reviewable. Id. at 344, 96 S.Ct. at 589.

In this case, the district court determined it lacked diversity jurisdiction because the amount in controversy did not meet the jurisdictional minimum set forth in 28 U.S.C. § 1332. This determination would seem to fall directly under Section 1447(c), and Section 1447(d) would prevent review. However, as discussed above, the district court exceeded its authority under § 1447(c) by relying upon a post-removal amendment to the complaint to determine the amount in controversy. Because the district court acted beyond the scope of its § 1447(c) authority, § 1447(d) does not act as a bar to appellate review. See In re: Bethesda Mem’ Hosp., Inc., 123 F.3d 1407, 1410 (11th Cir.1997) (noting “because the district court exceeded the grounds for remand contained in § 1447(c), § 1447(d) poses no bar to our review”); Trans Penn Wax Corp. v. McCandless, 50 F.3d- 217, 223 (3d Cir.1995) (holding “a remand -only falls under § 1447(c) if the removal itself was jurisdictionally improper, not if the defect arose after removal.... Remand decisions based on grounds other than ... that jurisdiction was improper at the time of removal ... are therefore reviewable ... as they do not implicate § 1447(c).”); Baldridge v. Kentucky-Ohio Trans., Inc., 983 F.2d 1341, 1348 (6th Cir.1992) (explaining if a district court “had thought that the removal had been jurisdictionally proper[*1292] but that jurisdiction had ‘vanished’ when [a party] dropped out, the remand — even though based on a finding of lack of jurisdiction — would be reviewable, as § 1447(c) envisions remands only for defective removal”); Amoco Petroleum, 964 F.2d at 708 (permitting appellate “review when the district judge believes that removal was proper and that later developments authorize remand”); but see Linton v. Airbus Industrie, 30 F.3d 592, 599 (5th Cir.1994) (concluding “that jurisdictional remands premised on post-removal events are not reviewable”). Upon our review of the record, as discussed above, we conclude the district court committed reversible error by remanding based on Appellees’ post-removal amended complaint.

III. CONCLUSION

The district court erred in remanding the case to the state court based on the amount recoverable alleged in Appellees’ amended complaint. Because the district court exceeded its authority pursuant to § 1447(c), § 1447(d) does not act as a bar to our review. Accordingly, we reverse and remand to the district court to determine whether it had subject matter jurisdiction at the time of removal.

REVERSED AND REMANDED.

1

. In discussing a different issue, we have noted the amendments to § 1447(c) were "legally insignificant” and were not intended to change the meaning of the original section. See Snapper v. Redan, 171 F.3d 1249, 1256-57 n. 14 (11th Cir.1999).

2

. We note that- other post-removal events, however, may divest the district court of jurisdiction. See, e.g., In re Merrimack Mut. Fire Ins. Co., 587 F.2d 642, 646 (5th Cir.1978) (holding that a district court must remand if indispensable parties have not been joined). This case is binding on this Court pursuant to Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir.1981) (en banc), in which this Court adopted as binding precedent all decisions of the former Fifth-Circuit handed down prior to close of business on September 30, 1981.

3

. 28 U.S.C. § 1447(d) reads as follows: "An order remanding a case to the State court from which it was removed is not reviewable on appeal or otherwise, except that an order remanding a case to the State court from which it was removed pursuant to section 1443 of this title shall be reviewable by appeal or otherwise.”