Woodbridge Pines Apartments LLC v. Chauncey White
8:17-cv-01724
C.D. Cal.Oct 6, 2017Background
- Plaintiff Woodbridge Pines Apartments LLC filed an unlawful detainer action in Orange County Superior Court to evict defendant Chauncey White and others.
- Defendants removed the unlawful detainer action to federal court asserting federal jurisdiction.
- The district court reviewed the Notice of Removal and state-court records sua sponte to evaluate subject-matter jurisdiction.
- Plaintiff’s complaint asserts only state-law unlawful detainer claims and alleges damages within the limited civil action bounds (under $25,000).
- Defendants relied on anticipated federal defenses and argued for removal; they did not establish diversity of citizenship for all parties or the $75,000 amount-in-controversy.
- The district court concluded it lacked federal-question and diversity jurisdiction and ordered remand to state court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Federal-question jurisdiction exists | Complaint raises only state-law unlawful detainer claims | Federal defenses/affirmative defenses create federal-question jurisdiction | No — federal-question depends on plaintiff’s complaint, not anticipated defenses; no federal-question jurisdiction |
| Removal is proper because of federal defense | N/A (plaintiff relies on state law) | Federal-law affirmative defenses justify removal | No — a federal defense does not render a state claim removable |
| Diversity jurisdiction exists | Parties are not completely diverse; amount in controversy is small | Removal defendant asserts diversity and sufficient amount in controversy | No — not all defendants are diverse from all plaintiffs; amount in controversy not plausibly > $75,000 and underlying action is limited civil < $25,000 |
| Court may raise jurisdiction sua sponte | Case should remain in state court absent valid federal basis | Removal was filed; court should retain case | Court must remand when lacking subject-matter jurisdiction and may do so sua sponte |
Key Cases Cited
- Syngenta Crop Protection, Inc. v. Henson, 537 U.S. 28 (federal removal is statutory and strictly construed)
- Great Northern R. Co. v. Alexander, 246 U.S. 276 (state suits remain in state court absent congressional removal grant)
- Franchise Tax Bd. v. Construction Laborers Vacation Trust, 463 U.S. 1 (federal defense does not create federal-question jurisdiction)
- ARCO Environmental Remediation, L.L.C. v. Department of Health and Environmental Quality, 213 F.3d 1108 (federal jurisdiction depends on plaintiff’s complaint, not anticipated defenses)
- Berg v. Leason, 32 F.3d 422 (affirmative federal-law defense does not render state action removable)
- Gaus v. Miles, Inc., 980 F.2d 564 (burden on removing defendant to establish jurisdiction)
- Abrego Abrego v. Dow Chemical Co., 443 F.3d 676 (removing party carries burden to prove jurisdiction)
- Nevada v. Bank of America Corp., 672 F.3d 661 (removal statutes construed narrowly)
- Dennis v. Hart, 724 F.3d 1249 (requirements and scope of §1441 removal)
- Kelton Arms Condominium Owners Ass’n v. Homestead Ins. Co., 346 F.3d 1190 (district court must remand if it lacks subject-matter jurisdiction)
- Emrich v. Touche Ross & Co., 846 F.2d 1190 (subject-matter jurisdiction is nonwaivable and may be raised sua sponte)