On July 22nd, the Third Circuit held that federal district courts have diversity jurisdiction to resolve issues arising from an error committed during the marshal's sale of real property ordered by the court. It therefore remanded to the district court the equitable question of whether to set aside a foreclosure sale because of a mistake - here, the failure of the first lien holder to notify the junior lien holder of the sale - made during foreclosure proceedings. National City Mortgage Co. v. Stephen.