Mohanna v. Wells Fargo Bank, N.A.

Background

Keyhan Mohanna, who was representing himself, filed this case against Wells Fargo Bank, N.A., and Dukes Partners II, LLC. He asserted claims for wrongful foreclosure, violations of California Commercial Code section 3302 and following sections, and quiet title.

Jurisdiction issue

The court explained that federal courts have limited jurisdiction. Federal-question jurisdiction requires a case to arise under the U.S. Constitution, federal laws, or treaties. Diversity jurisdiction can cover state-law claims only when the parties are citizens of different states and the amount in controversy exceeds $75,000, excluding interest and costs.

Mohanna's complaint stated that federal-question jurisdiction existed, but the court concluded that the complaint asserted only state-law claims. The court also stated that, based on documents filed with the California Secretary of State, it appeared that the court might not have diversity jurisdiction over the case. The opinion text does not provide a final determination of the parties' citizenship.

Order

The court ordered the parties to show cause—that is, to explain—why the case should not be dismissed for lack of subject-matter jurisdiction. It directed Mohanna, Wells Fargo, and Dukes Partners to file one-page letters by September 7, 2021, identifying any basis for federal jurisdiction and specifically explaining the citizenship of all parties.

The court vacated the August 26, 2021 hearing on the defendants' motions to dismiss and the initial case-management conference. It stated that the conference would be rescheduled later if necessary. The defendants were ordered to immediately serve Mohanna with the order and notify him by phone or email if possible. Judge Donna M. Ryu did not dismiss the case in this order.