U.S. Court of Appeals for the Eleventh Circuit

Kimberly Galvin v. Moliere Dimanche, Jr.

September 3, 2026

Summary

The Eleventh Circuit affirmed the district court’s order remanding the unlawful‑detainer action to Florida state court, holding that the defendant’s pro se removal under 28 U.S.C. §1443(1) was improper because he failed to show a manifest denial of his §1981 rights, and that the district court did not err by remanding rather than dismissing the case with prejudice.