Palmer v. City Nat. Bank, of West Virginia (2007)
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· 101 citation events
across 20 courts.
Showing the 50 strongest citers on record
(one row per citing case, strongest signal kept).
Treatment trajectory · 2008 → 2026 · click a year to view the case as of then
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Federal Home Loan Mortgage Corp. v. Gilbert (2016)
Va., 498 F.3d 236, 246 (4th Cir. 2007).
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Rodas v. Seidlin (2011)
Therefore, it is not surprising that federal courts have regularly considered the doctrine of derivative jurisdiction as relating to “removal jurisdiction.” Palmer, 498 F.3d at 248 (“removal jurisdiction is derivative of state court jurisdiction prior to removal”); In re Miles, 430 F.3d 1083, 1087 (9th Cir.2005) (considering derivative jurisdiction in removal-jurisdiction terms); Hollis v. Florida State Univ., 259 F.3d 1295 , 1298 (11th Cir.2001) (same); North Dakota v. Fred…
“removal jurisdiction is derivative of state court jurisdiction prior to removal”
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Thomas E. Reynolds v. Behrman Capital IV L.P. (2021)
Bank, 498 F.3d 236, 245 (4th Cir. 2007) (explaining the different views of the Fourth and Eighth Circuits).
explaining the different views of the Fourth and Eighth Circuits
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Skyline Tower Painting, Inc. v. Elizabeth Goldberg (2025)
Va., 498 F.3d 236, 240 (4th Cir. 2007) (“Whether at the suggestion of the parties or otherwise, this Court has an obligation to verify the existence of appellate jurisdiction before considering the merits of an appeal.”). 5 Some non-final decisions may also be appealed under § 1291 pursuant to the collateral order doctrine, “a ‘practical construction’ of § 1291’s ‘final decision rule,’ under which a ‘small class’ of decisions that do not end the litigation on the merits may …
“Whether at the suggestion of the parties or otherwise, this Court has an obligation to verify the existence of appellate jurisdiction before considering the merits of an appeal.”
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Elizabeth Goldberg v. Skyline Tower Painting, Inc. (2025)
Va., 498 F.3d 236, 240 (4th Cir. 2007) (“Whether at the suggestion of the parties or otherwise, this Court has an obligation to verify the existence of appellate jurisdiction before considering the merits of an appeal.”). 5 Some non-final decisions may also be appealed under § 1291 pursuant to the collateral order doctrine, “a ‘practical construction’ of § 1291’s ‘final decision rule,’ under which a ‘small class’ of decisions that do not end the litigation on the merits may …
“Whether at the suggestion of the parties or otherwise, this Court has an obligation to verify the existence of appellate jurisdiction before considering the merits of an appeal.”
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Elizabeth Goldberg v. Television Tower, Inc. (2025)
Va., 498 F.3d 236, 240 (4th Cir. 2007) (“Whether at the suggestion of the parties or otherwise, this Court has an obligation to verify the existence of appellate jurisdiction before considering the merits of an appeal.”). 5 Some non-final decisions may also be appealed under § 1291 pursuant to the collateral order doctrine, “a ‘practical construction’ of § 1291’s ‘final decision rule,’ under which a ‘small class’ of decisions that do not end the litigation on the merits may …
“Whether at the suggestion of the parties or otherwise, this Court has an obligation to verify the existence of appellate jurisdiction before considering the merits of an appeal.”
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Television Tower, Inc. v. Elizabeth Goldberg (2025)
Va., 498 F.3d 236, 240 (4th Cir. 2007) (“Whether at the suggestion of the parties or otherwise, this Court has an obligation to verify the existence of appellate jurisdiction before considering the merits of an appeal.”). 5 Some non-final decisions may also be appealed under § 1291 pursuant to the collateral order doctrine, “a ‘practical construction’ of § 1291’s ‘final decision rule,’ under which a ‘small class’ of decisions that do not end the litigation on the merits may …
“Whether at the suggestion of the parties or otherwise, this Court has an obligation to verify the existence of appellate jurisdiction before considering the merits of an appeal.”
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Phyllis Weaver v. Walgreen Company (2025)
Va., 498 F.3d 236, 240 (4th Cir. 2007).
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FX Aviation Capital LLC v. Hector Guerrero (2025)
Va., 498 F.3d 236, 240 (4th Cir. 2007).
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Randal Ricci v. Darrin Salzman (2020)
Va., 498 F.3d 236, 249 (4th Cir. 2007); see also Rodriguez v. United States, 788 F. App’x 535 , 536 (9th Cir. 2019); Patriot Cinemas, Inc. v. Gen.
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Randal Ricci v. Darrin Salzman (2020)
Va., 498 F.3d 236, 249 (4th Cir. 2007); see also Rodriguez v. United States, 788 F. App’x 535 , 536 (9th Cir. 2019); Patriot Cinemas, Inc. v. Gen.
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Brenda Noe v. City National Bank of West Virginia (2020)
Va., 498 F.3d 236, 240 (4th Cir. 2007).
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Timothy Demartini v. Michael Demartini (2020)
Va., 498 F.3d 236 , 242–43 (4th Cir. 2007) (“A district DEMARTINI V.
“A district DEMARTINI V. DEMARTINI 21 court decision that has a preclusive effect on the parties and that is logically and factually separable from the remand order is a decision that can be reviewed by this Court without affecting the remand order.”
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Jeffrey Nadel v. Elsie Marino (2018)
Va., 498 F.3d 236, 240-42 (4th Cir. 2007).
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Thomas Porter v. David Zook (2015)
Va., 498 F.3d 236, 240 (4th Cir.2007).
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Jesus Lopez v. Ramon Vaquera (2014)
Va., 498 F.3d 236, 246 (4th Cir. 2007) (“Whatever the intent of the 2002 amendment, its result was that § 1441(f) is more clear than former § 1441(e) in abrogating derivative jurisdiction only with respect to removals effectuated under § 1441.”) 7 Case: 13-50790 Document: 00512610597 Page: 8 Date Filed: 04/28/2014 No. 13-50790 States under the derivative jurisdiction doctrine. 16 IV Sentrillion also contends that the district court erred in remanding the state law claims tha…
“Whatever the intent of the 2002 amendment, its result was that § 1441(f) is more clear than former § 1441(e) in abrogating derivative jurisdiction only with respect to removals effectuated under § 1441.”
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Argenbright v. United States (2023)
Va., 498 F.3d 236, 239 (4th Cir. 2007).
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In re Show Cause Order Dated November 17, 2022 (2022)
Virginia, 498 F.3d 236, 244 (4th Cir. 2007)).
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Giovanni v. United States Department of the Navy (2017)
Va., 498 F.3d 236, 244 (4th Cir. 2007).
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Kelvin Fortenberry v. Office of the Legal Advisor (2025)
Bank, of West Virginia, 498 F.3d 236, 246 (4th Cir. 2007) (noting that Congress, in its statutory language, expressly abrogated derivative jurisdiction for removals effectuated under § 1441, but did not do so for cases removed under § 1442). when a suit lacking jurisdiction in state court is removed to federal court under § 1442.
noting that Congress, in its statutory language, expressly abrogated derivative jurisdiction for removals effectuated under § 1441, but did not do so for cases removed under § 1442
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Nielsen v. Miller (2021)
Va., 498 F.3d 236, 249 (4th Cir. 2007). 9 Even if the Court had subject matter jurisdiction over this action following the SBA’s removal to this Court pursuant to 28 U.S.C. § 1442 (a)(1), the Court would exercise its discretion to remand the remaining claims because (1) those claims involve issues of state law only, (2) the litigation is in its initial stages, and (3) Nielsen, the plaintiff, originally filed the action in Albemarle County Circuit Court, his forum of choice.
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Johnson v. Citibank, N.A. (2014)
Va., 498 F.3d 236, 244 (4th Cir.2007).
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Sherrylyn Mitchell v. Scott Tuner, Secretary, Department of Housing and Urban Development (2026)
Va., 498 F.3d 236, 239 (4th Cir. 2007).
Va., 498 F.3d 236, 239 (4th Cir. 2007).
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Long v. Department of Education (2025)
Va., 498 F.3d 236, 244 (4th Cir. 2007); Arizona v. Manypenny, 451 U.S. 232 , 242 n.17 (1981); see Williams v. Pretrial Servs.
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I-81, LLC v. FELHER TRANSPORTATION, INC. (2025)
Va., 498 F.3d 236, 246 (4th Cir. 2007).
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Liu v. U.S. Agency for International Development (2025)
Va., 498 F.3d 236, 244 (4th Cir. 2007) (explaining that the doctrine of derivative jurisdiction “arises from the theory that a federal court’s jurisdiction over a removed case derives from the jurisdiction of the state court from which the case originated”).
explaining that the doctrine of derivative jurisdiction “arises from the theory that a federal court’s jurisdiction over a removed case derives from the jurisdiction of the state court from which the case originated”
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Spicer v. U.S. Marshals of District of Columbia (2025)
Va., 498 F.3d 236, 244 (4th Cir. 2007).
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Franklin v. Social Security Administration (2024)
Virginia, 498 F.3d 236, 246 (4th Cir. 2007).
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McCain v. Social Security Administration (2023)
Va., 498 F.3d 236, 244 (4th Cir. 2007).
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Hymer-Griffith v. Kijakazi (2023)
No. 99-336, § 3 , 100 Stat. 633 , 637 (1986) (current version at 28 U.S.C. § 1441 (f)); Palmer v. City Nat’l Bank, 498 F.3d 236, 245 (4th Cir. 2007) (noting a circuit split until Congress’s 2002 amendment). removed under 28 U.S.C. § 1441 , leaving cases removed under other statutes—such as 28 U.S.C. § 1442 , the federal agency removal statute—still subject to the doctrine.17 Because Ms. H. proceeds pro se, her filings are liberally construed and “held to a less stringent sta…
noting a circuit split until Congress’s 2002 amendment
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Cummings v. United States Department of Justice (2023)
Virginia, 498 F.3d 236, 245 (4th Cir. 2007) (describing 1985 and 2002 amendments to § 1441), it has made no such parallel amendment to § 1442.
describing 1985 and 2002 amendments to § 1441
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Biron v. George (2023)
Virginia, 498 F.3d 236, 245 (4th Cir. 2007) (describing 1985 and 2002 amendments to § 1441), it has made no such parallel amendment to § 1442.
describing 1985 and 2002 amendments to § 1441
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Cobb v. Baker (2022)
Virginia, 498 F.3d 236, 245 (4th Cir. 2007) (describing 1985 and 2002 amendments to § 1441), it has made no such parallel amendment to § 1442.
describing 1985 and 2002 amendments to § 1441
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Patel v. Jones (2022)
Bank, of West Virginia, 498 F.3d 236, 239 (4th Cir. 2007) (“The doctrine of derivative jurisdiction requires that a federal court’s jurisdiction over a removed case mirror the jurisdiction that the state court had over the action prior to removal.”).
“The doctrine of derivative jurisdiction requires that a federal court’s jurisdiction over a removed case mirror the jurisdiction that the state court had over the action prior to removal.”
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Patel v. Jones (2022)
Bank, of West Virginia, 498 F.3d 236, 239 (4th Cir. 2007) (“The doctrine of derivative jurisdiction requires that a federal court’s jurisdiction over a removed case mirror the jurisdiction that the state court had over the action prior to removal.”).
“The doctrine of derivative jurisdiction requires that a federal court’s jurisdiction over a removed case mirror the jurisdiction that the state court had over the action prior to removal.”
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Patel v. Jones (2022)
Bank, of West Virginia, 498 F.3d 236, 239 (4th Cir. 2007) (“The doctrine of derivative jurisdiction requires that a federal court’s jurisdiction over a removed case mirror the jurisdiction that the state court had over the action prior to removal.”).
“The doctrine of derivative jurisdiction requires that a federal court’s jurisdiction over a removed case mirror the jurisdiction that the state court had over the action prior to removal.”
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Patel v. Jones (2022)
Bank, of West Virginia, 498 F.3d 236, 239 (4th Cir. 2007) (“The doctrine of derivative jurisdiction requires that a federal court’s jurisdiction over a removed case mirror the jurisdiction that the state court had over the action prior to removal.”).
“The doctrine of derivative jurisdiction requires that a federal court’s jurisdiction over a removed case mirror the jurisdiction that the state court had over the action prior to removal.”
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Patel v. Jones (2022)
Bank, of West Virginia, 498 F.3d 236, 239 (4th Cir. 2007) (“The doctrine of derivative jurisdiction requires that a federal court’s jurisdiction over a removed case mirror the jurisdiction that the state court had over the action prior to removal.”).
“The doctrine of derivative jurisdiction requires that a federal court’s jurisdiction over a removed case mirror the jurisdiction that the state court had over the action prior to removal.”
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Kinard v. United States (2022)
Virginia, 498 F.3d 236, 246 (4th Cir. 2007).
Virginia, 498 F.3d 236, 245 (4th Cir. 2007) (describing the subsequent amendments).
describing the subsequent amendments
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Falice v. O'Brien (2020)
Va., 498 F.3d 236, 244 (4th Cir. 2007).
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Woods v. Hawk-Sawyer (2020)
Va., 498 F.3d 236, 244 (4th Cir. 2007).
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Bilgo v. United States Postal Service (2020)
“This doctrine has been referred to as the doctrine of derivative jurisdiction.” Rodas, 656 F.3d at 615 (citing Palmer v. City Nat’l Bank, of West Virginia, 498 F.3d 236, 239 (4th Cir. 2007)).
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Kovari v. Brevard Extraditions, LLC (2019)
At a bate minimum, when a statutory classification neither employs a suspect distinction nor burdens the exercise of a fundamental constitutional right, that classification must be tationally telated to a legitimate state interest—a level of examination referred to as “rational basis scrutiny.” Palmer v. City Nat'l Bank, 498 F.3d 236, 247 (4th Cir. 2007).
Va., 498 F.3d 236, 245 (4th Cir. 2007). 9 28 U.S.C. § 1441 (f); Palmer, 498 F.3d at 245 . 10 Lopez v. Sentrillon Corp., 749 F.3d 347, 350-51 (5th Cir. 2014). 11 42 U.S.C. § 405 (g). gives federal district courts exclusive jurisdiction over judicial review of final decisions.'?
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Johnson v. D.C. Metro Transit Authority (2017)
Bank of West Virginia, 498 F.3d 236, 239 (4th Cir. 2007)).
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Merkulov v. United States Park Police (2014)
Bank of West Virginia, 498 F.3d 236, 239 (4th Cir. 2007).
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Selvaggio v. Horner (2014)
Co., 258 U.S. 377, 382 , 42 S.Ct. 349 , 66 L.Ed. 671 (1922); Palmer v. City Nat’l Bank, 498 F.3d 236, 245-48 (4th Cir.2007).
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Cofield v. United States of America (2014)
Va. 498 F.3d 236, 244 (4th Cir.2007) (“The derivative-jurisdiction doctrine arises from the theory that a federal court’s jurisdiction over a removed case derives from the jurisdiction of the state court from which the case originated”).