Nordhoff Darby, LLC v. Danielle Archuleta, 2:22-cv-01454

Plaintiff Nordhoff Darby LLC filed an unlawful detainer action in the Superior Court of California (Los Angeles County).
Defendants (including Danielle Archuleta) removed the action to federal court.
The district court reviewed the Notice of Removal and state-court record and found no basis for federal subject-matter jurisdiction.
Removing defendants relied on asserted federal defenses, an invocation of federal-question and bankruptcy jurisdiction, and attempted § 1443 removal; the court found each theory deficient.
The court concluded diversity jurisdiction and the amount-in-controversy requirement were not met (defendants include California citizens; the underlying action is limited and under $25,000).
The court sua sponte REMANDED the case to the California Superior Court for lack of subject-matter jurisdiction (order dated March 4, 2022).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the case presents a federal-question under 28 U.S.C. § 1331	State-law unlawful detainer only; no federal claim	Federal defenses / affirmative defenses raise a federal question	Denied — federal-question jurisdiction absent; federal defenses cannot supply jurisdiction
Whether removal is proper under 28 U.S.C. § 1443 (civil rights removal)	State court will enforce civil rights; no barrier asserted	Claims denial of enforcement of federal equal civil rights justifies removal	Denied — § 1443 requirements not met; defendant failed to show state courts would refuse to enforce federal rights
Whether diversity jurisdiction exists (28 U.S.C. § 1332) / amount in controversy	Complaint is a limited civil unlawful detainer under $25,000	Defendant claims amount in controversy and diversity	Denied — lack of complete diversity, plaintiff’s limited damages, and defendant’s California citizenship defeat diversity/removability
Whether other federal jurisdiction (e.g., bankruptcy § 1334) or procedural defects to removal exist	Underlying action is state unlawful detainer; no bankruptcy core issue	Removing party cited § 1334 and procedural grounds; removing party also not named defendant in state complaint	Denied — case does not arise under Title 11; procedural defects (removing party not a named defendant) further preclude removal

Syngenta Crop Prot., Inc. v. Henson, 537 U.S. 28 (2002) (removal is purely statutory and statutes authorizing removal are strictly construed)
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 claim, not anticipated defenses)
Franchise Tax Bd. v. Constr. Laborers Vacation Tr., 463 U.S. 1 (1983) (federal defenses do not render a state action removable)
Patel v. Del Taco, Inc., 446 F.3d 996 (9th Cir. 2006) (standards for § 1443 removal require showing state courts would deny enforcement of federal civil rights)
City of Greenwood v. Peacock, 384 U.S. 808 (1966) (§ 1443(2) limited to certain federal or state officers refusing to enforce state law)
Dart Cherokee Basin Operating Co. v. Owens, 574 U.S. 81 (2014) (burden/standard for amount-in-controversy allegations in removal notices)
Kelton Arms Condo. Owners Ass’n v. Homestead Ins. Co., 346 F.3d 1190 (9th Cir. 2003) (district court must remand when it lacks subject-matter jurisdiction)
Gaus v. Miles, Inc., 980 F.2d 564 (9th Cir. 1992) (removing defendant bears burden to establish federal jurisdiction)