KDF Citrus Tree LP v. James Thornton II, 2:19-cv-07961

Plaintiff KDF Citrus Tree L.P. filed an unlawful detainer action in Ventura County Superior Court; defendants removed the case to federal court.
The district court reviewed the notice of removal and state-court records and raised jurisdictional defects sua sponte.
The underlying action is an unlawful detainer (limited civil action) alleging damages under the $25,000 statutory cap.
Defendants asserted federal jurisdiction via federal-question theories (including anticipated federal defenses), §1443 civil-rights removal, and 28 U.S.C. § 1334 (bankruptcy) — none were supported by the record.
The court found lack of diversity (defendant is California citizen) and that the amount in controversy was not plausibly over $75,000.
Holding: the case was remanded to Ventura County Superior Court for lack of subject-matter jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Federal-question jurisdiction (28 U.S.C. § 1331)	State-law unlawful detainer; no federal claim pleaded	Federal issues arise from affirmative defenses and anticipated federal questions	Denied — federal jurisdiction depends on plaintiff’s claims, not defenses; no federal question presented
Removal based on federal defenses	N/A	Federal-law affirmative defenses convert case into federal question	Denied — a federal defense does not make a state claim removable (Franchise Tax Bd. rule)
Removal under 28 U.S.C. § 1443 (civil-rights removal)	N/A	Defendant claims denial/inability to enforce federal civil rights in state court	Denied — defendant failed to allege statutory/constitutional mandate showing state courts would not enforce rights; conclusory assertions insufficient
Diversity / amount in controversy (28 U.S.C. § 1332)	Complaint seeks limited damages under $25,000	Removal asserted amount and diversity met	Denied — defendant is California citizen (not diverse) and amount in controversy not plausibly > $75,000

Syngenta Crop Prot., Inc. v. Henson, 537 U.S. 28 (2002) (removal is statutory and must be strictly construed)
Great Northern Ry. Co. v. Alexander, 246 U.S. 276 (1920) (state suits remain in state court unless Congress provides removal)
Gaus v. Miles, Inc., 980 F.2d 564 (9th Cir. 1992) (burden on removing party; jurisdictional defects construed against removal)
ARCO Environmental Remediation, L.L.C. v. Department of Health & Environmental Quality, 213 F.3d 1108 (9th Cir. 2000) (removal depends on plaintiff’s complaint, not anticipated defenses)
Berg v. Leason, 32 F.3d 422 (9th Cir. 1994) (affirmative federal defense does not render state claim removable)
Franchise Tax Board v. Construction Laborers Vacation Trust, 463 U.S. 1 (1983) (federal defense cannot create federal-question jurisdiction)
Patel v. Del Taco, Inc., 446 F.3d 996 (9th Cir. 2006) (requirements for § 1443(1) removal and need for specific statutory/constitutional showing)
City of Greenwood v. Peacock, 384 U.S. 808 (1966) (§ 1443(2) is limited to federal officers and certain state officers refusing to enforce discriminatory laws)
Dart Cherokee Basin Operating Co. v. Owens, 574 U.S. 81 (2014) (plaintiff’s complaint controls amount-in-controversy; removing party must plausibly show jurisdiction)