Stephen King, et al. v. Eden Relocation, Inc., et al.

CourtDistrict Court, C.D. California
DecidedMarch 31, 2026
Docket2:26-cv-01408
StatusUnknown

This text of Stephen King, et al. v. Eden Relocation, Inc., et al. (Stephen King, et al. v. Eden Relocation, Inc., et al.) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Stephen King, et al. v. Eden Relocation, Inc., et al., (C.D. Cal. 2026).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 WESTERN DIVISION

12 STEPHEN KING, et al., No. 2:26-cv-01408-BFM 13 Plaintiff, v. ORDER DENYING MOTION 14 TO REMAND EDEN RELOCATION, INC., et al., 15 Defendants. 16

17 Before the Court is Plaintiff’s Motion to Remand. (ECF 8.) For the reasons 18 below, the Motion is denied. 19 I. Background 20 This action arises out of Plaintiff’s agreement with Hawaiian Van Lines 21 to ship his household goods from Oregon to Hawaii. (ECF 1-2 at 6-21 (Compl.).) 22 Plaintiff alleges that Defendants demanded payment that exceeded what the 23 parties had agreed to, delayed delivery, misled him about the nature of the 24 insurance coverage for the household goods, did not disclose that another 25 company would be responsible for performing the transportation, and damaged 26 the Porsche that had been entrusted to them for delivery. (Compl. ¶¶ 4-17.) 27 Plaintiff sued Eden Relocation, Inc. (dba Hawaiian Van Lines) and Universe 28 1 Systems, Inc. (dba Hawaiian Shipping) in the Los Angeles County Superior 2 Court, raising, among other things, breach of contract and fraud claims. (Compl. 3 at 1.) 4 On February 11, 2026, Defendants removed the matter to this Court, 5 citing both diversity of citizenship and federal question as the basis for federal 6 jurisdiction. (ECF 1 at 2-5.) In that notice of removal, Defendants stated that 7 the Carmack Amendment preempted Plaintiff’s state-law causes of action and 8 gave rise to federal question jurisdiction. (ECF 1 at 3-4.) 9 Plaintiff moved to remand this action, arguing that diversity of citizenship 10 does not provide a basis for removal, and that the only “federal question” was 11 presented by Defendants’ defense and not Plaintiff’s claims. (ECF 8-1 (Mot.); 12 ECF 11 (Reply).) Defendants opposed the Motion, contending that the Carmack 13 Amendment preempts Plaintiff’s state-law claims and that the complaint is 14 accordingly deemed to arise under federal law for jurisdictional purposes. (ECF 15 10 (Opp’n).) The matter is fully briefed and ready for decision. 16 II. Legal Standard 17 In general, “defendants may remove to the appropriate federal district 18 court ‘any civil action brought in a State court of which the district courts of the 19 United States have original jurisdiction.’” City of Chicago v. Int’l Coll. of 20 Surgeons, 522 U.S. 156, 163 (1997) (quoting 28 U.S.C. § 1441(a)). “The propriety 21 of removal thus depends on whether the case originally could have been filed in 22 federal court.” Id. 23 Federal courts have jurisdiction over two categories of cases: cases that 24 arise under federal law, 28 U.S.C. § 1331, and cases in which the amount in 25 controversy exceeds $75,000 and there is diversity of citizenship among the 26 parties, 28 U.S.C. § 1332(a). The two bases for jurisdiction serve distinct 27 purposes: “Federal-question jurisdiction affords parties a federal forum in which 28 ‘to vindicate federal rights,’ whereas diversity jurisdiction provides ‘a neutral 1 forum’ for parties from different States.” Home Depot U.S.A., Inc. v. Jackson, 2 587 U.S. 435, 438 (2019). Here, while Defendants’ notice of removal invokes 3 diversity jurisdiction, their Opposition makes clear that federal jurisdiction in 4 this case turns on federal question jurisdiction, not diversity. (Opp’n at 4.) 5 Regarding federal question jurisdiction, district courts have “original 6 jurisdiction of all civil actions arising under the Constitution, laws, or treaties 7 of the United States.” 28 U.S.C. § 1331; see also Grable & Sons Metal Prods., 8 Inc. v. Darue Eng’g & Mfg., 545 U.S. 308, 312 (2005) (federal question 9 jurisdiction is “invoked by and large by plaintiffs pleading a cause of action 10 created by federal law”). Federal question jurisdiction “is governed by the ‘well- 11 pleaded complaint rule,’ which provides that federal jurisdiction exists only 12 when a federal question is presented on the face of the plaintiff’s properly 13 pleaded complaint.” Caterpillar Inc. v. Williams, 482 U.S. 386, 392 (1987). A 14 case may not be removed to federal court based on the possibility of a federal 15 defense, even the defense of pre-emption and even if the defense is anticipated 16 in the plaintiff’s complaint. Id. at 393. 17 Under the corollary “artful pleading” doctrine, however, “a well-pleaded 18 state law claim” may “present[] a federal question when a federal statute has 19 completely preempted [a] particular area of law.” Hall v. N. Am. Van Lines, Inc, 20 476 F.3d 683, 687 (9th Cir. 2007) (citing Balcorta v. Twentieth Century-Fox Film 21 Corp., 208 F.3d 1102, 1107 (9th Cir. 2000)); see also Hansen v. Grp. Health 22 Coop., 902 F.3d 1051, 1057 (9th Cir. 2018) (quoting Rivet v. Regions Bank of La., 23 522 U.S. 470, 478 (1998)) (“[A] plaintiff may not defeat removal by omitting to 24 plead necessary federal questions.”). In an area of complete preemption, any 25 claim purportedly based on a preempted state law “is considered, from its 26 inception, a federal claim, and therefore arises under federal law.” Wayne v. 27 DHL Worldwide Express, 294 F.3d 1179, 1183 (9th Cir. 2002) (cleaned up); 28 Franchise Tax Bd. v. Constr. Laborers Vacation Trust for So. Cal., 463 U.S. 1, 1 24 (1983) (“[I]f a federal cause of action completely preempts a state cause of 2 action any complaint that comes within the scope of the federal cause of action 3 necessarily ‘arises under’ federal law”). In short, a “completely preempted claim 4 may be removed to district court under § 1441.” Hall, 476 F.3d at 687. 5 III. Discussion 6 Defendants do not claim that Plaintiff’s well-pleaded complaint contains 7 any federal claim. (ECF 1 at 2; Opp’n at 3-4.)1 The motion, then, turns on 8 whether the Carmack Amendment completely preempts Plaintiff’s state-law 9 causes of action. 10 The Carmack Amendment is a “federal statute that provides the exclusive 11 cause of action for interstate shipping contract claims.” White v. Mayflower 12 Transit, L.L.C., 543 F.3d 581, 584 (9th Cir. 2008) (citing Hall, 476 F.3d at 687- 13 88). It is among the limited number of statutes well-established to “completely 14 preempt” certain well-pleaded state claims involving such contracts. Hall, 476 15 F.3d at 687 (citing Beneficial Nat. Bank v. Anderson, 539 U.S. 1, 8 (2003)).

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Related

Caterpillar Inc. v. Williams
482 U.S. 386 (Supreme Court, 1987)
Rivet v. Regions Bank of Louisiana
522 U.S. 470 (Supreme Court, 1998)
Beneficial National Bank v. Anderson
539 U.S. 1 (Supreme Court, 2003)
Smallwood v. Allied Van Lines, Inc.
660 F.3d 1115 (Ninth Circuit, 2011)
United States v. Derek E. Yell
18 F.3d 581 (Eighth Circuit, 1994)
White v. Mayflower Transit, L.L.C.
543 F.3d 581 (Ninth Circuit, 2008)
White v. Mayflower Transit, LLC
481 F. Supp. 2d 1105 (C.D. California, 2007)
Karen Hansen v. Group Health Cooperative
902 F.3d 1051 (Ninth Circuit, 2018)
Home Depot U. S. A., Inc. v. Jackson
587 U.S. 435 (Supreme Court, 2019)
Balcorta v. Twentieth Century-Fox Film Corp.
208 F.3d 1102 (Ninth Circuit, 2000)

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Bluebook (online)
Stephen King, et al. v. Eden Relocation, Inc., et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/stephen-king-et-al-v-eden-relocation-inc-et-al-cacd-2026.