(UD) (PS) Stonegate Apartments L.P. v. Jackson, 2:25-cv-01077

Stonegate Apartments L.P. filed an unlawful detainer action under California state law against Dana Jackson in Sacramento County Superior Court.
Jackson removed the case to federal court, asserting federal question jurisdiction.
The complaint sought $7,169 in unpaid rent (plus $55.33/day from a specified date), categorizing the matter as a limited action under $10,000.
The district court raised the issue of subject matter jurisdiction sua sponte as required by precedent.
The core complaint only alleged state law claims; no federal claims were asserted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Federal Question Jurisdiction for Removal	No federal claim in complaint	Removal proper due to federal question	No federal question alleged; removal improper
Diversity Jurisdiction for Removal	Amount in controversy <$75,000	Presumed diversity jurisdiction	Amount in controversy insufficient for diversity
Supplemental Jurisdiction Applicability	Not invoked; no primary jurisdiction	Court may have supplemental jurisdiction	No original jurisdiction; supplemental statute inapplicable
Basis for Remand to State Court	Federal court lacks jurisdiction	Case can be heard in federal court	Remand to state court is mandatory

United Investors Life Ins. Co. v. Waddell & Reed, Inc., 360 F.3d 960 (9th Cir. 2004) (court must establish subject matter jurisdiction sua sponte)
Geographic Expeditions, Inc. v. Estate of Lhotka, 599 F.3d 1102 (9th Cir. 2010) (removal statute strictly construed against removal jurisdiction)
Hunter v. Philip Morris USA, 582 F.3d 1039 (9th Cir. 2009) (strong presumption against removal; all ambiguity resolved in favor of remand)
Caterpillar, Inc. v. Williams, 482 U.S. 386 (1987) (federal jurisdiction depends on plaintiff’s complaint, not on anticipated defenses)
Wayne v. DHL Worldwide Express, 294 F.3d 1179 (9th Cir. 2002) (federal defenses do not confer removal jurisdiction)