Essex Property Trust, Inc. v. Daniel Poore, et al.

Background

Essex Property Trust, Inc. filed an unlawful-detainer action against Daniel Poore, et al. in California state superior court. Daniel and Claudia Poore, who were representing themselves, removed the case to federal court. The opinion states that the removal relied on federal-question jurisdiction based on the federal Coronavirus Aid, Relief, and Economic Security Act and other federal defenses.

A magistrate judge recommended sending the case back to state court because the federal court lacked subject-matter jurisdiction, meaning authority to hear the case. No objections were filed before the deadline expired.

Jurisdiction Analysis

The court explained that a federal defense to a state-law eviction claim is not a basis for removal under federal-question jurisdiction. The same reasoning applied to the other federal defenses identified by the defendants. The court also agreed that diversity jurisdiction was unavailable because of the forum-defendant rule, which limits removal based on diversity when a defendant covered by that rule is sued in the relevant state.

Ruling

After independently reviewing the matter, Judge James Donato adopted the report and recommendation. The court ordered the case remanded to the Superior Court of California for the County of Marin and terminated all pending motions.