MERIDAN RIVER DEVELOPMENT CORPORATION
v.
ROSHANDA C. BYRD
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A defendant removed an eviction action from state court to federal court, claiming federal question jurisdiction based on a federal compulsory counterclaim. The district court held that federal counterclaims cannot establish federal question jurisdiction and remanded the case to state court for lack of subject matter jurisdiction.
The court held that a federal counterclaim, even when compulsory, does not establish 'arising under' jurisdiction sufficient to support federal question jurisdiction, and therefore the case must be remanded to state court.
[1] A federal counterclaim, even when compulsory, does not establish federal question jurisdiction for removal purposes.
[2] Federal courts are obligated to inquire into subject matter jurisdiction sua sponte whenever it may be lacking.
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Join FLexlaw to unlock all legal intelligence“A federal counterclaim, even when compulsory, does not establish 'arising under' jurisdiction.”
Establishes the legal principle that counterclaims cannot support federal question jurisdiction
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Join FLexlaw to unlock all legal intelligencePlaintiff Meridan River Development Corporation filed an eviction action against defendant Roshanda C. Byrd in Hillsborough County Circuit Court, Flor…
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This cause comes before the Court sua sponte.1 Plaintiff initially filed this eviction action in the County Court of the Thirteenth Judicial Circuit in and for Hillsborough County, Florida. (Doc. 1-1). On November 11, 2025, Defendant removed this case to federal court. (Doc. 1). Defendant asserts that removal is proper under federal question jurisdiction because she filed a federal compulsory counterclaim and defense. (Id.). But counterclaims cannot give rise to federal question jurisdiction. See Vaden v. Discover Bank, 556 U.S. 49, 61 (2009) (“[A] federal counterclaim, even when compulsory, does not establish ‘arising under’ jurisdiction.”) (citation omitted). Thus, the Court must remand this case because the Court lacks subject matter jurisdiction. 28 U.S.C. § 1447(c) (“If at any time before final judgment it
JOHN L. BADALAMENTI
UNITED STATES DISTRICT JUDGE
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Citator
Authorities Cited
- Cadet v. Bulger, 377 F.3d 1173 (11th Cir. 2004)
- Vaden v. Discover Bank, 556 U.S. 49 (U.S. 2009)