Catamount Properties 2018, LLC v. Selassie

CourtDistrict Court, D. Nevada
DecidedNovember 26, 2024
Docket2:24-cv-01834
StatusUnknown

This text of Catamount Properties 2018, LLC v. Selassie (Catamount Properties 2018, LLC v. Selassie) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Catamount Properties 2018, LLC v. Selassie, (D. Nev. 2024).

Opinion

4 UNITED STATES DISTRICT COURT 5 DISTRICT OF NEVADA 6

7 CATAMOUNT PROPERTIES 2018, LLC, Case No. 2:24-cv-01834-CDS-NJK 8 Plaintiff, REPORT AND RECOMMENDATION 9 v.

10 FRASBERG SELASSIE, 11 Defendant. 12 Pursuant to 28 U.S.C. § 1915, Defendant is proceeding in this action pro se and has 13 requested authority pursuant to § 1915 to proceed in forma pauperis.1 See Docket No. 1. 14 Defendant also filed a notice of removal. Docket No. 1-1. 15 I. Magistrate Judge Authority 16 The Court first evaluates its authority to address the matter. The authority of the 17 undersigned magistrate judge is derived from 28 U.S.C. § 636, which generally provides 18 magistrate judges with the authority to “hear and determine” non-dispositive matters. See 28 19 U.S.C. § 636(b)(1)(A); see also S.E.C. v. CMKM Diamonds, Inc., 729 F.3d 1248, 1259 (9th Cir. 20 2013). By contrast, dispositive matters are sometimes referred to magistrate judges, but in those 21 circumstances a magistrate judge submits a recommendation to the assigned district judge that is 22 subject to the district judge’s de novo review. See 28 U.S.C. § 636(b)(1)(B); see also CMKM 23 Diamonds, 729 F.3d at 1259-60. Section 636 specifically enumerates eight different types of 24 matters to be treated as “dispositive.” See 28 U.S.C. § 636(b)(1)(A)-(B). When a matter falls 25 outside of those expressly enumerated as dispositive, courts look to the nature and effect of the 26

27 1 Given the Court’s separate duty to ensure that it has subject matter jurisdiction over the dispute before it, the Court need not address whether Defendant qualifies to proceed in forma 28 pauperis. 1 issued ruling to determine whether the underlying matter should be considered dispositive or non- 2 dispositive. See, e.g., Maisonville v. F2 America, Inc., 902 F.2d 746, 748 (9th Cir. 1990). 3 The Ninth Circuit has held that remanding a case to state court, while not case-dispositive, 4 is dispositive of proceedings in federal court and is therefore beyond the authority of magistrate 5 judges. Flam v. Flam, 788 F.3d 1043, 1047 (9th Cir. 2015). As such, the undersigned will issue 6 a report and recommendation to the assigned district judge. See id. 7 II. Standards 8 Cases may be removed from state court to federal court based on the existence of federal 9 subject matter jurisdiction. 28 U.S.C. § 1441. The Court has a duty to ensure that it has subject 10 matter jurisdiction over the dispute before it, an issue it may raise at any time during the 11 proceedings. See, e.g., Fed. R. Civ. P. 12(h)(3). “Federal courts are courts of limited jurisdiction,” 12 Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377(1994), and there is a strong 13 presumption against removal jurisdiction, Gaus v. Miles, 980 F.2d. 564, 566 (9th Cir. 1992). 14 “[F]ederal jurisdiction must be rejected if there is any doubt as to the right of removal in the first 15 instance.” Id. Removing defendants bear the burden of establishing that removal is proper. Id. 16 “A federal court is presumed to lack jurisdiction in a particular case unless the contrary 17 affirmatively appears.” Stock West, Inc. v. Confederated Tribes of the Colville Reservation, 873 18 F.2d 1221, 1225 (9th Cir. 1989). 19 a. Federal Question Jurisdiction 20 “Removal based on federal-question jurisdiction is reviewed under the longstanding well- 21 pleaded complaint rule.” Hansen v. Grp. Health Coop., 902 F.3d 1051, 1057 (9th Cir. 2018). The 22 “well-pleaded complaint rule provides that federal jurisdiction exists only when a federal question 23 is presented on the face of the plaintiff’s properly pleaded complaint.” California ex rel. v. Locyer 24 v. Dynegy, Inc., 375 F.3d 831, 838 (9th Cir. 2003) (internal citations omitted). The federal issue 25 “must be disclosed upon the face of the complaint, unaided by the answer or by the petition for 26 removal.” Id. (internal citations omitted). Moreover, counterclaims cannot be used to establish 27 federal question jurisdiction. Vaden v. Discover Bank, 556 U.S. 49, 60 (2009). 28 1 Defendant’s notice of removal indicates that federal question jurisdiction exists because 2 Defendant brings a counterclaim for copyright infringement. Docket No. 1-1 at 2. Defendant’s 3 counterclaim alleging a violation of federal law cannot be used as a basis for federal question 4 jurisdiction. 5 b. Diversity Jurisdiction 6 To remove a state action to federal court based on diversity jurisdiction, a removing 7 defendant must show that the parties are completely diverse and that the matter in controversy 8 exceeds the sum or value of $75,000. 28 U.S.C. § 1332(a). Complete diversity of citizenship 9 under 28 U.S.C. § 1332 requires that each plaintiff must be a citizen of a different state than each 10 defendant. Morris v. Princess Cruises, Inc., 236 F.3d 1061, 1067 (9th Cir. 2001). 11 In determining whether the amount in controversy is met, courts first look to the complaint. 12 Ibarra v. Manheim Invests., Inc., 775 F.3d 1193, 1197 (9th Cir. 2015). “Generally, the sum 13 claimed by the plaintiff controls if the claim is apparently made in good faith.” Id. (internal 14 citations omitted). Here, Defendant does not attach the complaint, so the amount in controversy 15 is not facially apparent. See Docket. When it is not facially apparent from the complaint that the 16 jurisdictional threshold is met, a defendant must show, by a preponderance of the evidence, that 17 the amount in controversy exceeds $75,000. See Sanchez v. Monumental Life Ins. Co., 102 F.3d 18 398, 403-04 (9th Cir. 1996). Here, Defendant’s notice of removal consists of only conclusory 19 statements that the amount in controversy exceeds $75,000. Defendant submits that “Plaintiff’s 20 unlawful [contract] interference caused delays, additional costs, and significant financial damages 21 to Defendant, exceeding $75,000” and that Plaintiff stole Defendant’s personal property, which 22 had a total value that exceeds $75,000. Docket No. 1-1 at 3. Defendant must support his claim 23 for federal jurisdiction with specific facts, not conclusory statements. See Pegram v. Jamgotchian, 24 No. 3:12-cv-50-RCJ-VPC, 2012 WL 3929789, at *5 (D. Nev. Sept. 7, 2012).

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Related

Kokkonen v. Guardian Life Insurance Co. of America
511 U.S. 375 (Supreme Court, 1994)
Vaden v. Discover Bank
556 U.S. 49 (Supreme Court, 2009)
Trigueros v. Adams
658 F.3d 983 (Ninth Circuit, 2011)
Jose Ibarra v. Manheim Investments, Inc.
775 F.3d 1193 (Ninth Circuit, 2015)
Laura Flam v. Marshall Flam
788 F.3d 1043 (Ninth Circuit, 2015)
Ross-Simons of Warwick, Inc. v. Baccarat, Inc.
102 F.3d 12 (First Circuit, 1996)
Karen Hansen v. Group Health Cooperative
902 F.3d 1051 (Ninth Circuit, 2018)
Morris v. Princess Cruises, Inc.
236 F.3d 1061 (Ninth Circuit, 2001)

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Catamount Properties 2018, LLC v. Selassie, Counsel Stack Legal Research, https://law.counselstack.com/opinion/catamount-properties-2018-llc-v-selassie-nvd-2024.