Chiang v. Afifi

District Court, N.D. California·Decided April 9, 2025·No. 3:25-cv-02074·Unknown

Opinion

TINA CHIANG, Case No. 25-cv-02074-PHK

Plaintiff, REPORT AND RECOMMENDATION RE REMAND PURSUANT TO THE v. MANDATORY SCREENING REQUIREMENTS OF 28 U.S.C. SABRINA AFIFI, § 1915(E)(2)(B); ORDER REASSIGNING TO A DISTRICT Defendant. JUDGE; ORDER ON MOTIONS Re: Dkts. 2, 7, 9, 10, and 14

This is a wrongful detainer lawsuit removed to this Court from California Superior Court by pro se Defendant Sabrina Afifi (“Afifi”). [Dkt. 1]. The Court previously granted Defendant Afifi’s application to proceed in forma pauperis. [Dkt. 6]. The Court now undertakes the mandatory screening requirement of the Complaint under 28 U.S.C. § 1915(e)(2)(B). After carefully reviewing the notice of removal, and all companying documents including the original Complaint filed in California Superior Court, and for the reasons set forth herein, the undersigned finds remand is appropriate. Defendant Afifi has consented to the jurisdiction of a United States Magistrate Judge pursuant to 28 U.S.C. § 636(c), but Plaintiff Chiang has not yet filed a consent or declination form. Accordingly, the Court ORDERS that this case be reassigned to a District Judge for disposition. For the reasons discussed herein, the undersigned RECOMMENDS that the District Judge REMAND this action to the California Superior Court for the County of Alameda. Defendant Afifi in the California Superior Court for the County of Alameda, Case No. 25-cv- 109250. [Dkt. 1 at 10–16]. Defendant Afifi filed an Answer to the Complaint. Id. at 27–32. On February 27, 2025, Defendant Afifi filed a notice of removal of the action to this Court. [Dkt. 1]. Contemporaneously, she moved this Court for leave to proceed in forma pauperis. [Dkt. 2]. By a separate Order, the Court has granted Defendant Afifi’s request to proceed in forma pauperis. [Dkt. 6]. On March 11, 2025, Plaintiff Tina Chiang moved for remand and requested judicial notice. [Dkt. 7]. When a party is granted leave to proceed in forma pauperis under section 1915(a), the complaint in such action is subject to mandatory review by the Court under 28 U.S.C. § 1915(e)(2)(B). In a typical in forma pauperis case filed by a pro se indigent plaintiff, the mandatory screening of a complaint serves to ensure that such a plaintiff benefiting from the in forma pauperis statutory scheme has presented a complaint which is legally sufficient to proceed. Jefferson v. United States, 277 F.2d 723, 725 (9th Cir. 1960) (“The right to proceed in forma pauperis is not an unqualified one. It is a privilege, rather than a right.”) (citation omitted). While the indigent Defendant here (not the Plaintiff) has sought and been granted leave to proceed in forma pauperis, the plain language of Section 1915(e)(2)(B) makes clear that “the court shall dismiss the case” without regard to which party sought leave to proceed in forma pauperis under Section 1915(a). That is, Section 1915(e)(2)(B) does not limit the mandatory screening of a complaint only to those cases in which the plaintiff is proceeding in forma pauperis. And, like the case at bar, cases sought to be removed from state court by an indigent defendant to a federal district court are appropriately screened to determine whether or not such removal is proper, including whether or not federal subject matter jurisdiction exists. See, e.g., RM White LLC v. Ramirez, No. 24-CV-00485-SVK, 2024 WL 1051000 (N.D. Cal. Feb. 14, 2024) (granting Defendants’ in forma pauperis application and then proceeding to screen Plaintiff’s complaint finding lack of subject matter jurisdiction); cf. Crown Props., Inc. v. Primo, 2021 WL 197345 (W.D. Wash. Jan. 20, 2021), adopting Report and Recommendation, 2020 WL 8224953 (W.D. Wash. Dec. 18, 2020) (screening 1915(e)(2)(B), finding lack of subject matter jurisdiction, and denying Defendants’ in forma pauperis application as moot). A complaint is subject to sua sponte dismissal if the Court determines the complaint is “frivolous or malicious,” “fails to state a claim on which relief may be granted,” or “seeks monetary relief against a defendant who is immune from such relief.” 28 U.S.C. § 1915(e)(2)(B)(i)–(iii). A pro se plaintiff’s pleadings are liberally construed and afforded the “benefit of any doubt.” Watison v. Carter, 668 F.3d 1108, 1112 (9th Cir. 2012) (citation omitted). Because Defendant here seeks to remove the case from California state court to this federal court, the Defendant is the party seeking the benefit of litigating in this forum and thus effectively stands in the shoes of a complainant by submitting this action for decision in this Court. While technically the Plaintiff here is not pro se, as a practical application of Section 1915 in a removal case such as this and out of an excess of caution, the Court will liberally construe the pleadings (including the Complaint which is proposed to be removed to this Court) and afford the pro se removing party (the Defendant) here the benefit of any doubt. See Crown Props., 2020 WL 8224953 at *1-2 (screening “proposed complaint” in case removed from state court to federal court). Under section 1915, the legal standard for whether a complaint is “frivolous” is well-known: a “case is frivolous if it is ‘of little weight or importance: having no basis in law or fact.’” Andrews v. King, 398 F.3d 1113, 1121 (9th Cir. 2005) (citations omitted). A complaint should be dismissed as “frivolous” under section 1915 if the court lacks subject matter jurisdiction over the action. See Castillo v. Marshall, 207 F.3d 15, 15 (9th Cir. 1997) (citation omitted); Pratt v. Sumner, 807 F.2d 817, 819 (9th Cir. 19987) (recognizing the general proposition that a complaint should be dismissed as frivolous under section 1915 review where subject matter jurisdiction is lacking). In Pratt, the Ninth Circuit noted the distinction between section 1915’s “frivolousness” review for lack of subject matter jurisdiction as compared to section 1915’s review for failure to state a claim. Pratt, 807 F.2d at 819. “[F]ederal jurisdiction is not negated by the likelihood that a complaint may fail to state a cause of action, inasmuch as that is grounds for dismissal on the merits and not for lack of jurisdiction.” Id. “Dismissal for want of jurisdiction may occur, however, where a claim is ‘wholly As discussed herein, the Court lacks subject-matter jurisdiction over this dispute and that conclusion compels remand of this action back to Alameda County Superior Court. It is well-known that federal courts are courts of limited jurisdiction. New Frontier Inv. AG v. BitCenter, Inc., No. 23-MC-80154-PHK, 2024 WL 459070, at *2 (N.D. Cal. Feb. 6, 2024) (citing Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 (1994)). A defendant may remove a civil action filed in state court to federal district court where the district court would have had original jurisdiction over the action. See 28 U.S.C. § 1441(a). However, where a district court lacks subject-matter jurisdiction over an action, federal law requires that the action “shall be remanded.” See 28 U.S.C. §

Chiang v. Afifi, (N.D. Cal. 2025).

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