Centre 11 LLC v. Goldstein

Background

Centre 11 LLC filed a single unlawful-detainer claim against Steven Goldstein in the Santa Clara County Superior Court. Centre 11 alleged that it leased Goldstein real property in Mountain View, California, that he fell behind on rent, and that $5,156.22 was due as of April 30, 2023. Centre 11 also alleged that it served Goldstein with a written notice requiring him either to pay the amount due or surrender possession within three days, and that he did neither.

Goldstein removed the action to the U.S. District Court for the Northern District of California, asserting federal-question jurisdiction under 28 U.S.C. § 1331. The federal court issued an order directing him to explain why the case should not be sent back to state court.

Jurisdiction analysis

Federal-question jurisdiction generally exists when a federal question appears on the face of the plaintiff’s properly pleaded complaint. The court found that Centre 11’s complaint asserted only an unlawful-detainer claim under California law and therefore did not present a federal question on its face.

Goldstein’s response did not address jurisdiction. It asserted that he had defenses under the federal Protecting Tenants at Foreclosure Act. The court held that a federal defense cannot provide a basis for removing a case to federal court. It also noted that courts in the circuit routinely determine that the Act cannot establish federal-question jurisdiction when the plaintiff’s only claim is a California unlawful-detainer claim.

Ruling

The court found that it lacked federal subject-matter jurisdiction and ordered that the action be remanded to the Santa Clara County Superior Court. It also ordered the federal clerk to close the file. Judge Beth Labson Freeman signed the order on August 29, 2023.