MTGLQ Investors, LP v. Manuel C. Roxas, 8:17-cv-01826

Plaintiff MTGLQ Investors, LP filed an unlawful detainer action in Orange County Superior Court against Manuel C. Roxas and others.
Defendants removed the action to federal court, asserting federal jurisdiction based on federal defenses, Section 1334, Section 1443, and/or diversity.
The district court reviewed the Notice of Removal and state-court records sua sponte for subject-matter jurisdiction.
The complaint asserted only state-law unlawful detainer claims and did not plead a federal question or damages exceeding diversity thresholds.
Defendants are California citizens; the case is a limited civil unlawful detainer action (under $25,000).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Federal-question jurisdiction under 28 U.S.C. § 1331	Complaint raises only state-law claims	Federal defenses/affirmative defenses create federal question	Denied — federal question depends on plaintiff’s claim, not anticipated defenses; removability not shown
Removal under 28 U.S.C. § 1443 (civil-rights removal)	State court can enforce civil rights; removal unnecessary	Removal appropriate because federal rights will be denied or not enforced in state court	Denied — defendants did not allege facts showing state courts would deny enforcement or that requirements of §1443(1)/(2) are met
Bankruptcy jurisdiction under 28 U.S.C. § 1334	Underlying dispute relates to bankruptcy matters (implied)	Unlawful detainer governed by California law, not Title 11	Denied — action does not arise under Title 11
Diversity jurisdiction under 28 U.S.C. § 1332 / amount in controversy	N/A (plaintiff’s complaint limited)	Amount in controversy met; parties are diverse	Denied — defendants failed to show complete diversity and did not plausibly allege > $75,000; action limited to <$25,000; defendant is California citizen (forum defendant rule)

Syngenta Crop Prot., Inc. v. Henson, 537 U.S. 28 (federal removal is statutory and narrowly construed)
Franchise Tax Bd. v. Constr. Laborers Vacation Trust, 463 U.S. 1 (federal defense does not create federal-question jurisdiction)
ARCO Envtl. Remediation, L.L.C. v. Dep’t of Health & Envtl. Quality, 213 F.3d 1108 (jurisdiction depends on plaintiff’s complaint, not anticipated defenses)
Berg v. Leason, 32 F.3d 422 (affirmative federal-law defense does not render action removable)
Patel v. Del Taco, Inc., 446 F.3d 996 (requirements for removal under § 1443 and need to show state courts would deny federal rights)
Dart Cherokee Basin Operating Co. v. Owens, 574 U.S. 81 (plaintiff’s complaint controls amount-in-controversy inquiry for removal)

The Court concluded it lacked subject-matter jurisdiction and remanded the unlawful detainer action to Orange County Superior Court.