Jacob Edward Yeagle v. David Groffo, 5:19-cv-01745

Plaintiff Jacob E. Yeagle filed an unlawful detainer action in Riverside County Superior Court.
Defendants (including David Groffo) removed the action to federal court.
The state complaint asserted only state-law unlawful detainer claims; no federal question was pled.
Defendants relied on affirmative defenses invoking federal law and asserted removal jurisdiction.
The complaint alleges a limited civil unlawful detainer (under $25,000); diversity and amount-in-controversy were not plausibly established by defendants.
The district court sua sponte found lack of subject-matter jurisdiction and remanded the case to state court on September 18, 2019.

Issue	Yeagle's Argument	Groffo's Argument	Held
Whether federal-question jurisdiction exists	Complaint raises only state unlawful detainer claims	Federal issues arise from defendants' affirmative defenses	No — federal defenses do not create federal-question jurisdiction
Whether complete diversity exists	Parties are not all diverse	Removal satisfies diversity (asserted)	No — complete diversity not shown
Whether amount-in-controversy meets $75,000 threshold	Underlying case is limited civil under $25,000	Amount-in-controversy met (asserted)	No — defendants failed to plausibly allege >$75,000
Whether the court must remand if it lacks subject-matter jurisdiction	Case should remain in state court	Removal justified (asserted)	Court must remand sua sponte and did remand to state court

Syngenta Crop Protection, Inc. v. Henson, 537 U.S. 28 (2002) (removal is statutory and strictly construed)
Great Northern R. Co. v. Alexander, 246 U.S. 276 (1918) (suit begun in state court remains unless Congress provides removal)
Nevada v. Bank of Am. Corp., 672 F.3d 661 (9th Cir. 2012) (statutes construed against removal)
Gaus v. Miles, Inc., 980 F.2d 564 (9th Cir. 1992) (burden on removing party to show jurisdiction)
Dennis v. Hart, 724 F.3d 1249 (9th Cir. 2013) (defendant may remove civil actions where federal courts have original jurisdiction)
Abrego Abrego v. Dow Chem. Co., 443 F.3d 676 (9th Cir. 2006) (removing defendant bears burden of establishing federal jurisdiction)
Kelton Arms Condo. Owners Ass'n v. Homestead Ins. Co., 346 F.3d 1190 (9th Cir. 2003) (subject-matter jurisdiction may not be waived; remand required if lacking)
Emrich v. Touche Ross & Co., 846 F.2d 1190 (9th Cir. 1988) (court may raise lack of subject-matter jurisdiction sua sponte)
ARCO Envtl. Remediation, L.L.C. v. Dep't of Health & Envtl. Quality, 213 F.3d 1108 (9th Cir. 2000) (federal jurisdiction depends on plaintiff's claims, not anticipated defenses)
Berg v. Leason, 32 F.3d 422 (9th Cir. 1994) (affirmative federal-law defense does not render state action removable)
Franchise Tax Bd. v. Construction Laborers Vacation Trust, 463 U.S. 1 (1983) (federal defense, even if central, cannot create federal-question jurisdiction)