Eldee-K Rental Properties v. DIRECTV

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Eldee-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. View "Eldee-K Rental Properties v. DIRECTV" on Justia Law