Christiana Trust v. Beitbadal, 1:15-cv-01773

Plaintiff (Christiana Trust) filed an unlawful detainer action in Stanislaus County Superior Court; defendant (Monika Beitbadal) removed to federal court on November 24, 2015.
The state complaint asserts a single cause of action: unlawful detainer under California law.
Removal notice argued federal-question jurisdiction because the state notice referenced the Protecting Tenants at Foreclosure Act (12 U.S.C. § 5201), which defendant says creates a 90-day notice right and a defense to eviction.
The district court reviewed subject-matter jurisdiction sua sponte, noting the strict, presumption-against-removal standard governing § 1441 removals.
The court applied the well-pleaded-complaint rule: federal jurisdiction exists only when a federal question appears on the face of the plaintiff’s properly pleaded complaint.
The court found the federal statute was cited only in the notice to inform the defendant of rights and did not form part of plaintiff’s claim; thus no federal question existed and remand was required.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether federal-question jurisdiction exists	Complaint is a state unlawful detainer action (no federal claim)	Removal proper because notice referenced the Protecting Tenants at Foreclosure Act, raising a federal issue	No federal-question jurisdiction; removal improper
Whether reference to a federal statute in a notice converts the state claim into a federal claim	Plaintiff: reference merely informs defendant of rights; claim rests in state law	Defendant: statutory reference creates a federal controversy and defense preempts/removes case	Reference in notice does not convert or create a federal claim; it may be a defense only
Whether court must address subject-matter jurisdiction sua sponte	N/A (court duty)	N/A	Court must sua sponte determine jurisdiction and resolve any doubt in favor of remand
Whether remand is discretionary	Plaintiff: remand required if jurisdiction lacking	Defendant: implied that removal could stand absent explicit federal claim	Remand is mandatory under § 1447(c) when court lacks subject-matter jurisdiction

United Investors Life Ins. Co. v. Waddell & Reed, Inc., 360 F.3d 960 (9th Cir. 2004) (district court must sua sponte establish subject-matter jurisdiction)
Geographic Expeditions, Inc. v. Estate of Lhotka, 599 F.3d 1102 (9th Cir. 2010) (removal statute strictly construed against removal)
Gaus v. Miles, Inc., 980 F.2d 564 (9th Cir. 1992) (strong presumption against removal; ambiguities resolved for remand)
Caterpillar, Inc. v. Williams, 482 U.S. 386 (1987) (well-pleaded complaint rule: federal defenses do not create removal jurisdiction)
Bruns v. NCUA, 122 F.3d 1251 (9th Cir. 1997) (remand under § 1447(c) is mandatory)
Page v. City of Southfield, 45 F.3d 128 (6th Cir. 1995) (case must be dismissed when court lacks subject-matter jurisdiction)
Duncan v. Stuetzle, 76 F.3d 1480 (9th Cir. 1996) (federal jurisdiction must be rejected if any doubt exists)