Case Explained: In re PARKS DIVERSIFIED, L.P. DEBTOR TALON DIVERSIFIED HOLDINGS INC.; NORTH VALLEY MALL II

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-07-23 Docket: 8:24-cv-00227-SVW The ninth-circuit dismissed in part for lack of appellate jurisdiction and affirmed in part the district court’s judgment regarding appeals stemming from a bankruptcy case involving Park Diversified, L.P. The court held that it lacks jurisdiction to review the district court’s order remanding claims against certain defendants to state court, applying 28 U.S.C. § 1447(d), which prohibits appellate review of remand orders based on defects in removal procedure or lack of subject-matter jurisdiction, as established in *Things Remembered, Inc. v. Petrarca*. The court further affirmed the district court’s finding that the bankruptcy court possessed subject-matter jurisdiction over “core” bankruptcy claims and validly exercised ancillary jurisdiction to resolve non-core claims based on a stipulation retaining jurisdiction, citing *In re Gruntz* and *In re Valdez Fisheries Dev. Ass’n*. Additionally, the court affirmed the imposition of sanctions under Federal Rule of Civil Procedure 11, concluding that the district court did not abuse its discretion in deeming the appellants’ motion for rehearing frivolous given the clarity of the remand order. The practical consequence is that the case is remanded to the district court with instructions to carry out the order remanding the specified claims to state court, while the sanctions and findings regarding bankruptcy jurisdiction remain in effect. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.