City of Philadelphia v. Kevin Hand

CourtCourt of Appeals for the Third Circuit
DecidedMarch 12, 2026
Docket25-3246
StatusUnpublished

This text of City of Philadelphia v. Kevin Hand (City of Philadelphia v. Kevin Hand) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
City of Philadelphia v. Kevin Hand, (3d Cir. 2026).

Opinion

AMENDED DLD-089 NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ___________

No. 25-3246 ___________

CITY OF PHILADELPHIA; KRR CAPITAL LLC

v.

KEVIN GREGORY HAND, Appellant ____________________________________

On Appeal from the United States District Court for the Eastern District of Pennsylvania (D.C. Civil No. 2:25-cv-05998) District Judge: Honorable Harvey Bartle III ____________________________________

Submitted for Possible Dismissal Due to a Jurisdictional Defect or Summary Action Pursuant to Third Circuit LAR 27.4 and I.O.P. 10.6 February 26, 2026 Before: RESTREPO, PORTER, and MONTGOMERY-REEVES, Circuit Judges

(Opinion filed March 12, 2026) _________

OPINION* _________

PER CURIAM

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. Kevin Gregory Hand appeals pro se and in forma pauperis from the District

Court’s orders remanding this matter to state court for want of jurisdiction and denying

reconsideration. We will summarily affirm.

I.

This appeal concerns Hand’s efforts to remove foreclosure and ejectment actions

from the Court of Common Pleas of Philadelphia County to the United States District

Court for the Eastern District of Pennsylvania. According to Hand, the City of

Philadelphia foreclosed upon his property at 18 South 55th Street in October 2023 in

response to unpaid taxes. He avers that “[t]he property was sold at a sheriff’s sale on

December 18, 2024, with the sheriff’s deed acknowledged on May 29, 2025, initiating a

nine-month redemption period concluding on February 28, 2026.” See ECF Doc. 2 at 2;

see generally City of Phila. v. El, et al., Case No. 2310T0101, Dkt. at 2-4 (Pa. Ct. Com.

Pl. Phila. Cnty.) (“Foreclosure Action Docket”). On September 4, 2025, representatives

of KRR Capital, LLC, the entity that purchased the property at the sheriff’s sale, brought

an ejectment action against Hand and the property’s other occupants. The Common Pleas

Court entered default judgment in KRR’s favor on October 29. See KRR Capital, LLC v.

All Occupants of 18 South 55th, Case No. 250900655, Dkt. at 4 (Pa. Ct. Com. Pl. Phila.

Cnty.) (“Ejectment Action Docket”).1

1 Although the state court dockets were not part of the record in the District Court, we may take judicial notice of them. See Orabi v. Att’y Gen., 738 F.3d 535, 537-38 (3d Cir. 2014); In re Congoleum Corp., 426 F.3d 675, 679 n.2 (3d Cir. 2005). 2 Meanwhile, Hand removed both actions to the District Court on October 17, 2025,

citing both the general removal statute, 28 U.S.C. § 1441, and the federal officer removal

statute, id. § 1442(a)(1), the latter on the ground that “the Director of Philadelphia

County Court of Common Pleas Prothonotaries and Tax Claim Bureau may have acted

under federal land patent authority, raising a federal defense.” See ECF Doc. 2 at 1, 5.

Approximately two weeks later, the court remanded the matter sua sponte pursuant to

28 U.S.C. § 1447(c) for lack of subject-matter jurisdiction. The court concluded that it

lacked jurisdiction because the underlying actions did not involve federal questions and

the parties were not diverse. Notwithstanding Hand’s intention to raise defenses and

counter- and crossclaims under federal law, the court explained that such assertions

would not “create federal court jurisdiction or render the otherwise unremovable case

removable.” See id. (citing, inter alia, Holmes Grp., Inc. v. Vornado Air Circulation Sys.,

Inc., 535 U.S. 826, 832 (2002)). Hand filed a timely motion for reconsideration, which

the District Court denied as moot. Hand appeals.2

2 After filing his notice of appeal, Hand filed in the District Court an emergency motion for preliminary injunction, citing “Eviction = homelessness, PTSD, loss of trust property” as irreparable harms. See ECF Doc. 12 at 2. The court dismissed his motion because the action had been remanded. Hand did not appeal that dismissal. Instead, he filed a federal complaint on behalf of himself and the property’s other occupants against the City, the Sheriff’s Office, KRR, and others under, inter alia, 42 U.S.C. § 1983, seeking to void the 2024 sheriff’s sale and enjoin any evictions efforts. See Hand v. City of Philadelphia, No. 2:25-cv-06863, Doc. 1 (E.D. Pa. Dec. 8, 2025). 3 II.

We have jurisdiction pursuant to 28 U.S.C. §§ 1291 and 1447(d).3 We review de

novo the District Court’s decision to remand for lack of subject-matter jurisdiction.

Maglioli v. All. HC Holdings LLC, 16 F.4th 393, 403 (3d Cir. 2021). Orders denying

reconsideration are reviewed for abuse of discretion. See United States v. Dupree, 617

F.3d 724, 732 (3d Cir. 2010) (citing Max’s Seafood Café ex rel. Lou-Ann, Inc. v.

Quinteros, 176 F.3d 669, 673 (3d Cir. 1999)). We may summarily affirm the District

Court’s judgment if the appeal fails to present a substantial question. See Murray v.

Bledsoe, 650 F.3d 246, 247 (3d Cir. 2011) (per curiam).

III.

Hand maintains that the District Court had federal question jurisdiction under

42 U.S.C. § 1983 and 28 U.S.C. § 1331. See C.A. Doc. 8 at 1. He also asserts that

“[c]omplete diversity now exists . . . due to Appellant’s lawful expatriation on

November 08, 2011.” See id. (citing “Exhibit: Cancellation of the Citizenship and ERC-

3 An order remanding a matter back to state court typically “is not reviewable on appeal or otherwise,” but that jurisdictional bar does not apply to cases removed pursuant to 28 U.S.C. §§ 1442 or 1443. See 28 U.S.C. § 1447(d). Hand cited Section 1442 as one of his bases for removal. That bare citation was sufficient to secure our jurisdiction to review the entire remand order. See BP P.L.C. v. Mayor & City Council of Balt., 593 U.S. 230, 141 S. Ct. 1532, 1538 (2021) (“Once [a defendant cites Section 1442 in a notice of removal] and the district court ordered the case remanded to state court, the whole of its order became reviewable on appeal.”). We also can review the order denying Hand’s motion for reconsideration. Cf. Agostini v. Piper Aircraft Corp., 729 F.3d 350, 353 (3d Cir.

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