CINCINNATI - Because a federal court erred in determining that it lacked subject matter jurisdiction over a lawsuit filed by Chase Bank USA N.A. and several other financial institutions that sought injunctive and declaratory relief from two other lawsuits filed by the City of Cleveland, a Sixth Circuit U.S. Court of Appeals panel on Sept. 26 reversed and remanded for further proceedings due to the lower court's dismissal sua sponte for failure to state a claim without notice to the parties involved (Chase Bank USA N.A., et al. v. City of Cleveland, Nos. 10-4115 and 10-4116, 6th Cir.).