Camden USA, Inc. v. Dezinae Carson, 2:18-cv-00724

Plaintiff Camden Harbor View filed an unlawful detainer action in Los Angeles County Superior Court against defendant Dezinae Carson.
Defendant removed the action to federal court asserting various bases for federal jurisdiction.
The state-court complaint contains only state-law unlawful detainer claims and does not plead any federal causes of action.
Defendant relied on anticipated federal defenses, 28 U.S.C. § 1443 (civil-rights removal), 28 U.S.C. § 1334 (bankruptcy jurisdiction), and diversity/amount-in-controversy as grounds for removal.
The district court reviewed the notice of removal and state-court record and raised jurisdictional deficiencies sua sponte.
The court concluded it lacked subject-matter jurisdiction and remanded the case to state court under 28 U.S.C. § 1447(c).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether federal-question jurisdiction exists under 28 U.S.C. § 1331	Complaint asserts only state-law unlawful detainer	Removal justified by anticipated federal defenses	No federal-question jurisdiction; federal defenses do not create removal basis
Whether removal is proper under 28 U.S.C. § 1443 (civil-rights removal)	State courts can adjudicate rights; no federal right asserted in complaint	§ 1443 allows removal because defendant cannot enforce federal civil-rights in state court	§ 1443 not satisfied; defendant failed to identify statutory/constitutional command showing state courts would deny enforcement
Whether bankruptcy jurisdiction exists under 28 U.S.C. § 1334	Action is a state unlawful detainer governed by California law	Removal invokes § 1334 (Title 11)	No § 1334 jurisdiction; action does not arise under Title 11
Whether diversity jurisdiction/amount-in-controversy supports removal under 28 U.S.C. § 1332	Complaint alleges less than $75,000 and limited civil action	Defendant claims diversity/amount satisfied	Diversity jurisdiction lacking: not all parties diverse and amount-in-controversy not plausibly met; unlawful detainer is a limited action under $25,000

Syngenta Crop Prot., Inc. v. Henson, 537 U.S. 28 (federal removal depends on plaintiff's claim)
Great Northern Ry. Co. v. Alexander, 246 U.S. 276 (removal is statutory privilege)
Nevada v. Bank of Am. Corp., 672 F.3d 661 (removal statutes construed narrowly)
Gaus v. Miles, Inc., 980 F.2d 564 (burden on removing party to establish jurisdiction)
Abrego Abrego v. Dow Chem. Co., 443 F.3d 676 (removing party bears burden to show jurisdiction)
ARCO Envtl. Remediation, L.L.C. v. Dep’t of Health & Envtl. Quality, 213 F.3d 1108 (jurisdiction depends on plaintiff’s claims, not anticipated defenses)
Franchise Tax Bd. v. Construction Laborers Vacation Trust, 463 U.S. 1 (federal defenses do not authorize removal)
Patel v. Del Taco, Inc., 446 F.3d 996 (requirements for removal under § 1443)
City of Greenwood v. Peacock, 384 U.S. 808 (§ 1443(2) limited to federal officers and related situations)