The case JPMorgan Chase Bank, N.A. v. Richard Caires., 17-2912-cv (2d Cir. 2019) involves a state court foreclosure action with a complex and detailed procedural history involving multiple bankruptcy filings, state court appeals and federal removal actions. The matter came to the Second Circuit by way of the foreclosure defendant’s third removal to the federal district court. The District Court judge, at the urging of Brian Rich, counsel for the defendant, but without a formal remand motion, ultimately issued an order of remand to the Connecticut Superior Court. On appeal, the borrower argued, with support from other Circuits, that the district court lacked authority to remand the case in the absence of a pending motion for remand. After briefing and oral argument, the Second Circuit affirmed the District Court’s ruling and dismissed the petition. In addition to the fact that the case has significant monetary value, the Second Circuit was given the opportunity to address important procedural implications of the federal removal scheme, although its ultimate decision may have less impact than anticipated.