Santa Ana Pacific Associates v. Ahmad Ayubi

I. Background

Plaintiff initiated what appears to be a routine unlawful detainer action against Defendant in Orange County Superior Court. On June 21, 2024, Defendant removed this action to federal court, asserting federal question jurisdiction. See generally Notice of Removal (“Not.”) (dkt. 1).

II. Legal Standard

“Any civil action of which the district courts have original jurisdiction founded on a claim or right arising under Constitution, treaties or laws of the United States shall be removable without regard to the citizenship or residence of the parties.” 28 U.S.C. § 1441(b). Whether a claim arises under federal law for removal purposes is determined by the same “well-pleaded complaint rule,” which provides that federal jurisdiction exists only when a federal question is presented on the face of the plaintiff's properly pleaded complaint. See Caterpillar, Inc. v. Williams, 482 U.S. 386, 392 (1987); Rivet v. Regions Bank of Louisiana, 522 U.S. 470, 475 (1998). “This rule makes a plaintiff the master of his complaint: it allows him to avoid federal jurisdiction by relying exclusively on state law.” Balcorta v. Twentieth Century–Fox Film Corp., 208 F.3d 1102, 1107…