Background
William Goulette, proceeding pro se, appealed a district court judgment dismissing his diversity action alleging breach of contract against United Wholesale Mortgage. The underlying dispute concerned real property located in New Hampshire.
The court’s reasoning
The panel reviewed the dismissal de novo and affirmed based on the local action doctrine, which vests exclusive jurisdiction over actions involving real property in the forum where that property is located. The court found the substance of the action related to real property under state law. Additionally, the district court did not abuse its discretion in denying a motion for default judgment because the defendant timely filed a motion to dismiss, which altered the answer deadline. The court also affirmed the denial of motions to vacate and for reconsideration, noting Goulette failed to establish a basis for relief and that arguments raised for the first time on appeal are not considered.
What it means going forward
The ruling reinforces that federal courts lack jurisdiction over local actions concerning real property located in another state, even when the contract was made or the cause of action accrued elsewhere.