Verbena WRC 15th LP v. Jesse Scott

Summary

The United States District Court for the Central District of California ordered remand of an unlawful detainer action removed from Los Angeles County Superior Court. The court held that unlawful detainer is a state-law cause of action and that the defendant failed to establish federal-question jurisdiction or respond to the order to show cause.

Holdings

1. The court lacked subject matter jurisdiction because the complaint asserted only an unlawful detainer claim, which is purely a matter of state law and does not support federal-question jurisdiction.
2. Remand to Los Angeles County Superior Court was required because the federal court lacked subject matter jurisdiction.

Questions Presented

1. Whether the federal 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