Summary
The court issued an order to show cause concerning subject matter jurisdiction in a removed unlawful detainer action. Because the complaint asserts only a state-law unlawful detainer claim, the court directed the defendants to explain why the case should not be remanded to Los Angeles County Superior Court.
Topics
Practice areas
Questions Presented
- Whether the federal court had subject matter jurisdiction over a removed unlawful-detainer action asserting only a state-law claim.
Holdings
- An unlawful-detainer action asserting only a state-law claim does not, on the record presented, establish federal-question jurisdiction; such actions are strictly within the province of state court.
Key quotations
“[T]he complaint only asserts a claim for unlawful detainer, a cause of action that is purely a matter of state law.”
“Unlawful detainer actions are strictly within the province of state court.”
Factual background
U.S. Bank Trust Company filed an unlawful-detainer action against Alfonso Luna, Otilia Luna, and Doe defendants in California state court. The complaint asserted only an unlawful-detainer claim. Defendants removed the action, contending that federal-question jurisdiction existed.
Procedural history
Plaintiff filed the unlawful-detainer action in Los Angeles County Superior Court on January 7, 2025. Defendants removed the action to the Central District of California on December 18, 2025, asserting jurisdiction under 28 U.S.C. §§ 1331 and 1443. The district court concluded that jurisdiction appeared lacking and ordered defendants to show cause in writing by January 28, 2026, why the case should not be remanded.
Remand instructions
Defendants were ordered to show cause in writing, on or before January 28, 2026, why the action should not be remanded to Los Angeles County Superior Court. The order did not itself remand the case.