Maguire Properties 755 S Fig LLC v. Donovan Grant

Summary

The United States District Court for the Central District of California remanded an unlawful detainer action to Los Angeles County Superior Court. The court held that unlawful detainer is a state-law claim and that it lacked subject-matter jurisdiction, noting that the defendant failed to respond to the order to show cause.

Holdings

1. A federal district court lacks subject matter jurisdiction over an action asserting only an unlawful detainer claim because unlawful detainer is a state-law claim within the province of state court.
2. When a removed unlawful detainer action presents no federal question and the federal court therefore lacks subject matter jurisdiction, the court must remand the action to state court.

Questions Presented

1. Whether the federal district court had subject matter jurisdiction over a removed action asserting only a state-law unlawful detainer claim.
2. Whether the action should be remanded to Los Angeles County Superior Court.

Disposition

remanded