Here is the petition in Smith v. People of the State of New York:
Smith v New York Cert Petition
The question presented:
Whether the statutory bar restricting removal jurisdiction is a separate and distinct removal jurisdiction, and a waivable procedural defect, by the failure to file a motion to remand with the 30 day statutory time limitation provided in 28 U.S.C. § 1447(c)?
Turtle Talk 