Elite Oil Field Enterprises, Inc. v. Reed, 979 F.3d 857 (10th Cir. Nov. 3, 2020)

The Tenth Circuit held, as a matter of first impression, that the statutory bar to appellate review of remand order based on lack of subject matter jurisdiction found in 28 U.S.C. § 1447(d) applies to remand orders resulting from post-removal joinder of defendants that destroyed diversity jurisdiction. The defendants had argued the bar applies only to cases remanded under § 1447(c), not § 1447(e) as in this case.