Jose Estrada v. The Irvine Company, LLC, 8:24-cv-01209

Plaintiff Jose Estrada, who uses a wheelchair, filed a lawsuit in Orange County Superior Court against The Irvine Company LLC, Irvine Spectrum Portfolio LLC, and unnamed defendants (Does 1-10).
The complaint alleged a violation of the Unruh Civil Rights Act (California Civil Code § 51), specifically regarding the lack of wheelchair-accessible outdoor dining tables at a public accommodation operated by defendants.
Plaintiff's claim referenced compliance standards from the Americans with Disabilities Act (ADA), asserting that defendants' failure to provide accessible tables violated federal law and thus the Unruh Act.
Defendants removed the case to U.S. District Court, citing federal question jurisdiction due to those ADA references.
The court evaluated its own subject matter jurisdiction as required, regardless of whether the parties disputed it.
The District Court sua sponte found it lacked subject matter jurisdiction and remanded the case to state court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does referencing ADA violations in an Unruh Act claim create federal question jurisdiction?	Plaintiff alleges a violation of state law (Unruh Act) with federal law (ADA) as an element of proof.	Defendants argue the complaint presents a federal question due to express ADA references.	Mere reference to ADA as an element of a state claim does not confer federal jurisdiction.
Is there a basis for federal diversity jurisdiction?	Not addressed by plaintiff.	No diversity jurisdiction asserted or established in removal notice.	No basis for diversity jurisdiction established.
May a district court remand sua sponte for lack of subject matter jurisdiction?	Not directly addressed by plaintiff.	Not directly addressed by defendant.	Yes, courts have an obligation to remand if jurisdiction is lacking.
Should the case remain in federal court or be remanded to state court?	Seeks state court adjudication of Unruh Act claim.	Seeks federal court adjudication based on alleged federal question.	Remanded to state court for lack of jurisdiction.

Gunn v. Minton, 568 U.S. 251 (threshold requirement for federal court jurisdiction)
Steel Co. v. Citizens for a Better Env’t, 523 U.S. 83 (federal courts’ jurisdictional obligations are inflexible)
Arbaugh v. Y&H Corp., 546 U.S. 500 (courts must independently ensure jurisdiction exists)
Caterpillar Inc. v. Williams, 482 U.S. 386 (federal jurisdiction requires a federal question on the complaint’s face)
Carden v. Arkoma Assocs., 494 U.S. 185 (diversity jurisdiction and LLC citizenship)
Owen Equip. & Erection Co. v. Kroger, 437 U.S. 365 (requirement of complete diversity for diversity jurisdiction)