Catamount Properties 2018, LLC v. Selassie

District Court, D. Nevada·Decided November 26, 2024·No. 2:24-cv-01834·Unknown

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEVADA

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

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

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

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

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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)