Troicky v. Lundeen

CourtDistrict Court, N.D. Ohio
DecidedFebruary 26, 2025
Docket1:25-cv-00367
StatusUnknown

This text of Troicky v. Lundeen (Troicky v. Lundeen) is published on Counsel Stack Legal Research, covering District Court, N.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Troicky v. Lundeen, (N.D. Ohio 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION

GEORGE TROICKY, ) Case No. 1:25-cv-367 ) Plaintiff, ) Judge J. Philip Calabrese ) v. ) Magistrate Judge ) Jennifer Dowdell Armstrong JAMES LUNDEEN, et al., ) ) Defendants. ) )

OPINION AND ORDER In January 2025, Plaintiff George Troicky filed suit in municipal court against Defendants James Lundeen, Cynthia Lundeen, and Sir Isaac Newton Enterprises, LLC. In his complaint, Plaintiff brings a single claim for forcible entry against Defendants, alleging that they are residing at premises Plaintiff owns without the right to possess or occupy the property. (ECF No. 1-2, PageID #25–26.) Plaintiff seeks restitution and an order that Defendants vacate the premises. (Id, PageID #27.) On February 24, 2025, Defendants removed the case to federal court. (ECF No. 1.) They did so on the basis of federal question jurisdiction under 28 U.S.C. § 1331. ANALYSIS Federal courts have limited jurisdiction, possessing only that power the Constitution and Congress authorize. Kokkonen v. Guardian Life Ins. Co. of America, 511 U.S. 375, 377 (1994). A defendant may remove a case to federal court only if it could have been filed there in the first place. Strong v. Teletronics Pacing Sys., Inc., 78 F.3d 256, 256 (6th Cir. 1996). Because of the limited jurisdiction of the federal courts, the Court has an independent obligation to examine its jurisdiction to ensure that it has the authority to proceed. See, e.g., Nikolao v. Lyon, 875 F.3d 310, 315 (6th

Cir. 2017) (citations and quotations omitted); Mercurio v. American Express Centurion Bank, 363 F. Supp. 2d 936, 938 (N.D. Ohio 2005). “[F]ederal courts have a duty to consider their subject matter jurisdiction in regard to every case and may raise the issue sua sponte.” Answers in Genesis of Ky., Inc. v. Creation Ministries Int’l, Ltd., 556 F.3d 459, 465 (6th Cir. 2009). Courts strictly construe the removal statute and resolve all doubts in favor of remand. Eastman v. Marine Mech. Corp.,

438 F.3d 544, 549–50 (6th Cir. 2006). To determine if federal jurisdiction exists, courts rely on the “well pleaded complaint rule.” Whether a claim arises under federal law, turns on the well-pleaded allegations of the complaint and ignores potential defenses. Beneficial Nat’l Bank v. Anderson, 539 U.S. 1, 6 (2003); Louisville & Nashville R.R. Co. v. Motley, 211 U.S. 149, 152 (1908). Complete preemption and the artful-pleading doctrine serve as exceptions to the well-pleaded complaint rule. Mikulski v. Centerior Energy Corp.,

501 F.3d 555, 560 (6th Cir. 2007). Another exception might be available in certain circumstances where State-law causes of action contain significant federal issues. Id.; see also Dillon v. Medtronic, Inc., 992 F. Supp. 2d 751, 756 (E.D. Ky. 2014). I. Complete Preemption Defendants invoke federal jurisdiction arguing that federal law preempts Plaintiff’s State-law claim. Specifically, it maintains that 28 U.S.C. § 1738, which provides for authentication and admission of official documents in proceedings in State courts so that the official acts of one jurisdiction receive full faith and credit in another, completely preempts a cause of action for forcible entry because Section 2329.022 of the Ohio Revised Code, governing the filing and authentication of foreign

judgments, references the federal statute. (ECF No. 1, ¶¶ 75–78, PageID #17.) In its entirety, Section 2329.022 provides: A copy of any foreign judgment authenticated in accordance with section 1738 of Title 28 of the United States Code, 62 Stat. 947 (1948), may be filed with the clerk of any court of common pleas. The clerk shall treat the foreign judgment in the same manner as a judgment of a court of common pleas. A foreign judgment filed pursuant to this section has the same effect and is subject to the same procedures, defenses, and proceedings for reopening, vacating, or staying as a judgment of a court of common pleas and may be enforced or satisfied in same manner as a judgment of a court of common pleas. A defendant’s ability to prove that a plaintiff’s claims are preempted as an affirmative defense does not provide a basis for removal of a case to federal court. Caterpillar, 482 U.S. at 398. Absent application of the well-pleaded complaint rule, removal requires complete preemption. “Complete preemption is jurisdictional and is ‘reserved for statutes designed to occupy the regulatory field with respect to a particular subject and to create a superseding cause of action[.]’” Bolton v. Gallatin Ctr. for Rehab. & Healing, LLC, 535 F. Supp. 3d 709 (M.D. Tenn. 2021) (quoting Roddy, 395 F.3d at 323). Complete preemption applies only where a federal statute contains the exclusive cause of action for the asserted claim and provides procedures and remedies regarding that cause of action. Beneficial Nat’l Bank, 539 U.S. at 8. The Sixth Circuit recognizes that complete preemption provides a very limited exception to the well-pleaded complaint rule, which is “only applied when the federal statutory language demonstrates that Congress has manifested a clear intent that claims not only be preempted under the federal law, but also that they be removable[.]” Palkow v. CSX Transp., Inc., 431 F.3d 543, 553 (6th Cir. 2005). Here, Section 1738 falls far short—far far short—of the high bar for complete preemption.

The statute gives no indication that it preempts any substantive State-law cause of action at all—let alone that any such claim should be removable to federal court. In only three circumstances has the Supreme Court recognized complete preemption: (1) the Labor Management Relations Act, 29 U.S.C. § 185; (2) the Employee Retirement Income Security Act, 29 U.S.C. § 1001; and (3) the National Bank Act, 12 U.S.C. §§ 85 & 86. See Beneficial Nat’l Bank, 539 U.S. at 6–11; see also Matthews, 15

F.4th at 721. The Full Faith and Credit statute does not come close to providing the type of comprehensive statutory regime any of these acts do. The statute does not provide nor do Defendants provide any additional evidence or argument that the Full Faith and Credit statute establishes an exclusive federal cause of action.

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Related

Louisville & Nashville Railroad v. Mottley
211 U.S. 149 (Supreme Court, 1908)
Kokkonen v. Guardian Life Insurance Co. of America
511 U.S. 375 (Supreme Court, 1994)
John T. Eastman v. Marine Mechanical Corporation
438 F.3d 544 (Sixth Circuit, 2006)
Mikulski v. Centerior Energy Corp.
501 F.3d 555 (Sixth Circuit, 2007)
Mercurio v. American Express Centurion Bank
363 F. Supp. 2d 936 (N.D. Ohio, 2005)
Tara Nikolao v. Nick Lyon
875 F.3d 310 (Sixth Circuit, 2017)
Dillon v. Medtronic, Inc.
992 F. Supp. 2d 751 (E.D. Kentucky, 2014)

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Bluebook (online)
Troicky v. Lundeen, Counsel Stack Legal Research, https://law.counselstack.com/opinion/troicky-v-lundeen-ohnd-2025.