DJ Mobile, LLC v. Andre Murphy

Summary

The United States District Court for the Eastern District of California remands an unlawful detainer action to Sacramento County Superior Court. The court holds that the defendant's federal defenses and asserted civil-rights issues do not create federal-question jurisdiction, and that diversity jurisdiction is unavailable because the amount in controversy is below $75,000 and complete diversity was not established.

Holdings

1. Removal was improper because the plaintiff's complaint pleaded only a state-law unlawful detainer claim and did not present a federal question on its face; the defendant's anticipated or asserted federal defenses could not establish federal-question jurisdiction.
2. Removal was also improper on a diversity theory because Murphy failed to establish complete diversity and failed to show by a preponderance of the evidence that the amount in controversy exceeded $75,000.
3. The case had to be remanded to Sacramento County Superior Court because the federal court lacked subject matter jurisdiction.

Questions Presented

1. Whether the federal court had federal-question jurisdiction over a state-law unlawful detainer action when the defendant relied on federal law as a defense.
2. Whether the federal court had diversity jurisdiction when the removing defendant failed to establish complete diversity and the amount in controversy exceeded $75,000.
3. Whether the action had to be remanded under 28 U.S.C. § 1447(c) for lack of subject matter jurisdiction.

Disposition

remanded