Case Explained: CYRUS SANAI V. DARREN COBRAE

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-06-16 Docket: 2:22-cv-00528-KJM-CKD The Ninth Circuit affirmed the district court’s dismissal of Cyrus Mark Sanai’s civil suit for lack of subject matter jurisdiction. The court held that the district court correctly determined it lacked federal question jurisdiction because Sanai failed to allege state action required under 42 U.S.C. § 1983; the defendant, Darren Cobrae, was not a state official nor acting in concert with the state, meaning the alleged due process violations could not be fairly attributed to the State of California. Additionally, the court affirmed the dismissal for lack of diversity jurisdiction, noting that Sanai’s complaint explicitly stated both parties were California residents at the time of filing, and the appellate court could not impute allegations of diverse citizenship based on post-filing relocation claims that contradicted the face of the pleadings. Consequently, the case was dismissed without reaching the merits of Sanai’s other claims. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.