FTE NETWORKS, INC., et al. v. MICHAEL BEYS, et al.

CourtDistrict Court, D. Nevada
DecidedOctober 29, 2025
Docket2:25-cv-01927
StatusUnknown

This text of FTE NETWORKS, INC., et al. v. MICHAEL BEYS, et al. (FTE NETWORKS, INC., et al. v. MICHAEL BEYS, et al.) 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
FTE NETWORKS, INC., et al. v. MICHAEL BEYS, et al., (D. Nev. 2025).

Opinion

1 UNITED STATES DISTRICT COURT

2 DISTRICT OF NEVADA

3 FTE NETWORKS, INC., et al., Case No. 2:25-CV-01927-ART-EJY 4 Plaintiffs, ORDER 5 vs. 6 MICHAEL BEYS, et al., 7 Defendants. 8

9 Plaintiffs and Defendants both claim to control FTE Networks, Inc. 10 Plaintiffs sued Defendants in state court, seeking a declaratory judgment that 11 they were the rightful directors and officers of FTE, and a writ of mandamus 12 compelling Defendants to hand over corporate books, records and other 13 property. (ECF No. 1-3.) In their complaint, Plaintiffs generally alleged that 14 Defendant Michael Beys had filed ultra vires petitions to place FTE subsidiaries 15 into Chapter 7 bankruptcy proceedings. (Id.) Upon Plaintiffs’ motion, the state 16 court partially granted and partially denied a Temporary Restraining Order, 17 tailoring relief to avoid interfering with the bankruptcy cases. (ECF Nos. 6-3, 14- 18 2.) Defendants subsequently removed the action to this Court. (ECF No. 1.) At a 19 hearing on October 24, 2025, this Court denied Plaintiffs’ Emergency Motion to 20 Remand (ECF No. 5) and granted their Emergency Motion to Enter a TRO. (ECF 21 No. 6.) This order follows. 22 I. Removal 23 As this case is bankruptcy-related and comes within the exclusive 24 jurisdiction of the federal courts, this Court finds that removal is proper. See 28 25 U.S.C. §§ 1452(a), 1334. 26 While removals are subject to various procedural requirements, 28 U.S.C. 27 §1441, the parties only dispute whether this Court has subject matter 1 jurisdiction. Plaintiffs contend that there is no federal subject matter jurisdiction 2 because the causes of action pleaded in the complaint do not “aris[e] under the 3 Constitution, laws or treaties of the United States” within the meaning of 28 4 U.S.C. § 1331. Under that statute, there is no federal question jurisdiction unless 5 the complaint pleads a federal cause of action, or where an issue of federal law 6 is an essential and actually disputed element of a pleaded state cause of action. 7 See Grable & Sons Metal Prods., Inc. v. Darue Eng'g & Mfg., 545 U.S. 308, 311 8 (2005). But here, because this case is closely linked to ongoing bankruptcy 9 proceedings, federal jurisdiction exists notwithstanding 28 U.S.C. § 1331. 10 A case’s sufficiently close relationship to bankruptcy may give a federal 11 court a basis for subject matter jurisdiction. See 28 U.S.C. §§ 1452(a), 1334. The 12 federal courts have removal jurisdiction where Plaintiffs’ claims fall “under” title 13 11, or “aris[e] under” or “aris[e] in” a title 11 proceeding. 28 U.S.C. § 1334(b). 14 Here, Plaintiff’s claim for declaratory judgment “aris[es] under” title 11 because 15 it is a state law cause of action that is completely preempted by the Bankruptcy 16 Code. In re Miles, 430 F.3d 1083, 1093 n.4 (9th Cir. 2005). Unlike other forms of 17 preemption, complete preemption gives federal courts jurisdiction over what 18 would otherwise be a state court complaint. MSR Expl., Ltd. v. Meridian Oil, Inc., 19 74 F.3d 910, 912 (9th Cir. 1996). The rationale for bestowing jurisdiction on 20 completely preempted state claims is that “[t]he Supreme Court has concluded 21 that the preemptive force of some federal statutes is so strong that… any claim 22 purportedly based on that preempted state law is considered, from its inception, 23 a federal claim, and therefore arises under federal law.” In re Miles, 430 F.3d at 24 1088 (citing Metro. Life Ins. Co. v. Taylor, 481 U.S. 58, 63 (1987)). When 25 determining if a cause of action related to bankruptcy is completely preempted, 26 courts in the Ninth Circuit inquire whether Congress intended the bankruptcy 27 statutes to provide the exclusive cause of action for the remedy sought. Id.; see 1 have the federal courts administer bankruptcies when they created statutes 2 giving the federal courts exclusive jurisdiction over suits under title 11, codified 3 a comprehensive and exhaustive scheme for administering bankruptcies in title 4 11, and enshrined the uniformity of the bankruptcy scheme in the Constitution). 5 Generally, complaints seeking relief for the improper filing of bankruptcy 6 petitions are completely preempted by the Bankruptcy Code. “The filings of 7 bankruptcy petitions are a matter of exclusive federal jurisdiction” because 8 Congress has specifically precluded state courts from creating their own 9 standards as to when persons may properly seek relief in bankruptcy. Gonzales 10 v. Parks, 830 F.2d 1033, 1035 (9th Cir. 1987). “Parties injured by wrongful 11 bankruptcy court filings must look to the Bankruptcy Code and rules for 12 redress.” In re Bral, 622 B.R. 737, 744 (2020). The Ninth Circuit has expressed 13 concern that without preemption, the opportunities for attacking bankruptcy 14 proceedings through state claims such as malicious prosecution “would only be 15 limited by the fertility of the pleader's mind and by the laws of the state in which 16 the proceeding took place.” MSR Expl., 74 F.3d. at 914. 17 The Ninth Circuit Bankruptcy Appellate Panel’s opinion in In re Bral 18 establishes that the Bankruptcy Code preempts state tort claims made against 19 someone for allegedly filing voluntary bankruptcy petitions in excess of their 20 authority. 622 B.R. at 744 n.5. That case grew out of a dispute occurring after 21 one co-manager of a corporation improperly brought the corporation into 22 voluntary Chapter 11 bankruptcy without a second co-manager’s signature, 23 consent, or joint authorization. Id. The bankruptcy court dismissed for lack of 24 authorization. Id. at 744, 741. Later, the first co-manager filed another voluntary 25 Chapter 11 bankruptcy petition. Id. At 741. The second co-manager (acting 26 through another corporate entity) appeared in the new case and claimed to the 27 bankruptcy court that he was owed damages for abuse of process and tortious 1 caused the vacatur of a valuable foreclosure sale. Id. The Panel ruled that the 2 Bankruptcy Code preempted the second co-manager’s state law allegations. Id. 3 at 742. Examining the relevant precedent, the Panel found that it and the Ninth 4 Circuit “[o]n a number of occasions… held that the Bankruptcy Code and Rules 5 completely preempt state law causes of action and remedies arising from the act 6 of filing a bankruptcy.” Id. at 743. Although the second co-manager argued that 7 the first co-manager should not benefit from the preemptive effect of the 8 Bankruptcy Code because he had repeatedly brought improper claims under 9 that statute, that defense was not availing. Id. Neither did it matter that the 10 second co-manager's remedies under the Bankruptcy Code would be 11 substantially different than under state law. Id. The Panel suggested that the 12 proper remedy under the Bankruptcy Code would have been 11 U.S.C. § 362

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FTE NETWORKS, INC., et al. v. MICHAEL BEYS, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/fte-networks-inc-et-al-v-michael-beys-et-al-nvd-2025.