Keshava LLC v. Goyens
- William Orrick
- 3:25-cv-01462
- U.S. District Court · Northern District of California
- 2
In Keshava LLC v. Goyens, Judge Orrick granted Goyens’s fee-waiver application but dismissed and remanded the unlawful-detainer case for lack of federal jurisdiction.
Keshava LLC and Chaledeeannka Goyens; the case was returned to the Alameda County Superior Court, and Goyens’s application to proceed without paying filing fees was granted.
What happened
Keshava LLC v. Goyens began as an unlawful-detainer case in California state court. Goyens removed it to federal court and asked to proceed without paying filing fees.
The court found no basis for federal jurisdiction. It concluded that the parties were both California residents, defeating diversity jurisdiction, and that a state-law unlawful-detainer claim does not arise under federal law.
Judge William H. Orrick granted Goyens’s application to proceed without paying filing fees, but dismissed the case and remanded it to the Alameda County Superior Court. The Clerk was ordered to close the file.
The detailed version
- Keshava LLC v. Goyens · No. 3:25-cv-01462
- William Orrick
- Feb. 20, 2025
Background
Keshava LLC filed an unlawful-detainer action against Chaledeeannka Goyens in California state court. Goyens removed the case to the U.S. District Court for the Northern District of California on February 12, 2025, and applied to proceed in forma pauperis, meaning without paying the usual court filing fees.
Jurisdiction
The court explained that a party may generally remove a state-court case, but the federal court must have subject-matter jurisdiction. The removing defendant bears the burden of identifying a basis for that jurisdiction.
The court concluded that the removal notice did not identify a valid basis. It found no diversity jurisdiction because the notice and state-court complaint indicated that both parties were California residents. It also found no federal-question jurisdiction because a state-law unlawful-detainer claim does not arise under federal law.
Disposition
The court granted Goyens’s application to proceed in forma pauperis. Because there was no federal jurisdiction over the unlawful-detainer complaint, the court dismissed the case and remanded it to the Alameda County Superior Court. The Clerk was ordered to close the file.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.