Eldee-K Rental Properties v. DIRECTV, No. 11-17994 (9th Cir. 2014)
Annotate this CaseEldee-K filed suit against DIRECTV, alleging that DIRECTV has a policy of installing satellite reception equipment in common areas of apartment buildings and other dwelling units without the landlord's consent. Eldee-K sought to certify a class of all landlords who own and lease residential multiple dwelling units in the United States on which DIRECTV installed equipment based on Part 2 of its installation form. The district court dismissed Eldee-K's claims with prejudice, holding that the local action doctrine deprived it of jurisdiction to adjudicate the claim where the key harm in the complaint related to trespass on real property situated in Connecticut. The court concluded that the local action doctrine was jurisdictional; the court was bound by California law as to when an action constituted a local action for purposes of considering the court's jurisdiction; Eldee-K's allegations and the relief sought in its complaint indicated that the essence of Eldee-K's Unfair Competition Law, Cal. Bus. & Prof. Code 17200-10, claim was a trespass, which was a local action under California law; and because the real property at issue is in Connecticut, the district court lacked subject matter jurisdiction to adjudicate Eldee-K's action. Accordingly, the court affirmed the judgment of the district court.
Court Description: Jurisdiction. The panel affirmed the district court’s Fed. R. Civ. P. 12(b)(1) dismissal for lack of subject matter jurisdiction of Eldee-K Rental Properties, LLC’s complaint against DIRECTV, Inc. Eldee-K, which owns a residential apartment building in Connecticut, sought to certify a class of all landlords who own and lease residential multiple dwelling units in the United States on which DIRECTV installed equipment. The local action doctrine vests exclusive jurisdiction over specified types of actions involving real property in the forum where the property is located. The panel held that the local action doctrine is jurisdictional. The panel also held that it was bound by California law as to when an action constituted a local action for purposes of considering the court’s jurisdiction. The panel held that Eldee-K’s action was a local action under California law, and therefore had to be brought in Connecticut where the real property at issue was located.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.