In Barlow v. Colgate Palmolive Co., Nos. 13-1840, 13-1839 (4th Cir. Apr. 30, 2014), plaintiffs sued Colgate and other defendants in Maryland state court, alleging that their products had exposed plaintiffs to asbestos.  Notwithstanding the presence of two non-diverse defendants, Colgate removed to federal court, arguing that plaintiffs intended to pursue claims against only Colgate and that the other defendants had been fraudulently joined.  After plaintiffs’ counsel represented that there were viable claims against the non-diverse defendants, the district court remanded the case.  Thereafter, plaintiffs informed the state court they were pursuing only those claims based upon Colgate’s products.  Colgate moved in the district court for a vacatur of the remand order as a sanction.  The district court denied the motion and the Fourth Circuit, in a divided opinion, affirmed.  The majority held that the federal courts lack power to revoke a remand because a remand order divests a district court of all jurisdiction and precludes it from entertaining any further proceedings of any character.  Moreover, under the plain language of the removal statute, remands based on a lack of subject matter jurisdiction are not reviewable on appeal or otherwise.  The court concluded that if Congress wanted to carve out an attorney-misconduct exception to the prohibition on review of remand orders, it would have done so expressly in the statute.