Unreported / Non-Citable
Background
CPT Argyle Apartments LLC filed an unlawful detainer action against Nicholas Matranga in the Los Angeles County Superior Court, case number 26STUD05196. Matranga, the defendant, then removed the action to the U.S. District Court for the Central District of California under case number 2:26-cv-11601 and simultaneously filed a Request to Proceed In Forma Pauperis. The plaintiff later filed a Motion to Remand, docketed as Dkt. 7. The court's October 29, 2026 order resolved both the fee request and the jurisdictional dispute in a single decision.
Because the case arrived by removal, the removing defendant bore the burden of establishing federal jurisdiction. Subject matter jurisdiction may not be waived, and the district court must remand if it lacks jurisdiction. Only state-court actions that originally could have been filed in federal court may be removed by a defendant; absent diversity of citizenship, federal-question jurisdiction is required.
The court reviewed the Notice of Removal and the state-court complaint and concluded that it lacked jurisdiction over the action. It then analyzed the two possible bases for jurisdiction in turn: diversity of citizenship under 28 U.S.C. § 1332(a) and federal-question jurisdiction under 28 U.S.C. § 1331.
The Court’s Holding
Diversity jurisdiction was lacking. The state-court complaint sought damages not exceeding $10,000, and the defendant suggested no plausible allegations that the amount in controversy exceeded the sum or value of $75,000 exclusive of interest and costs, as required for diversity jurisdiction under 28 U.S.C. § 1332(a). A routine unlawful detainer claim of that size cannot satisfy the statutory threshold.
Federal-question jurisdiction was also lacking. The complaint did not raise a claim arising under the Constitution, laws, or treaties of the United States as required by 28 U.S.C. § 1331. Because landlord-tenant disputes are matters of state law, an action for eviction cannot be the basis for federal-question jurisdiction. The court further noted that federal jurisdiction depends solely on the plaintiff's claims for relief, not on anticipated defenses to those claims, and cannot rest upon an actual or anticipated counterclaim.
In sum, the court denied the Request to Proceed In Forma Pauperis and remanded the action to the state court. The plaintiff's Motion to Remand was denied as moot because the court had independently determined that remand was required.
Key Takeaways
- A removing defendant bears the burden of establishing federal jurisdiction, and failure to do so requires remand because subject matter jurisdiction cannot be waived.
- Diversity jurisdiction requires an amount in controversy exceeding $75,000 exclusive of interest and costs; a complaint seeking damages not exceeding $10,000 does not meet that threshold.
- Landlord-tenant disputes and eviction actions arise under state law and cannot support federal-question jurisdiction under 28 U.S.C. § 1331.
- Federal jurisdiction depends solely on the plaintiff's claims for relief, not on anticipated defenses or on an actual or anticipated counterclaim.
- A plaintiff's motion to remand may be denied as moot when the court independently concludes that remand is required for lack of subject matter jurisdiction.
Why It Matters
This order illustrates the strict limits on removal jurisdiction in low-value, state-law landlord-tenant disputes. Even when a defendant removes a case and seeks to proceed in forma pauperis, the district court must independently confirm its own subject matter jurisdiction, and a routine unlawful detainer action seeking no more than $10,000 belongs in state court.
The ruling also shows how removal practice interacts with threshold screening: the court resolved the jurisdictional question, denied the in forma pauperis request, remanded the action, and rendered the plaintiff's own motion to remand moot. For practitioners, the practical lesson is that removal of a garden-variety eviction case will fail absent a genuine federal question or the required amount in controversy.