Case Explained: GOULETTE V. UNITED WHOLESALE MORTGAGE, LLC

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-06-25 Docket: 9:24-cv-00175-DWM The Ninth Circuit affirmed the district court’s dismissal of William Goulette’s diversity action alleging breach of contract against United Wholesale Mortgage. The court held that the district court correctly applied the local action doctrine, which vests exclusive jurisdiction over actions involving real property in the state where the property is located. Because Goulette’s complaint concerned real property in New Hampshire and the relief sought related to the title or status of that land, the Montana federal court lacked subject matter jurisdiction regardless of where the contract was made or the cause of action accrued. The appellate court further ruled that the district court did not abuse its discretion in denying Goulette’s motion for a default judgment, as the defendant had timely filed a Rule 12(b)(1) motion to dismiss, which altered the deadline for filing an answer and demonstrated an intent to defend. Additionally, the court affirmed the denial of Goulette’s motions to vacate the dismissal order and for reconsideration, finding he failed to establish any basis for relief under Federal Rules of Civil Procedure 59(e) and 60(b). The court rejected Goulette’s arguments regarding caption errors in the motion to dismiss and improper docketing as meritless, and declined to consider allegations raised for the first time on appeal. All pending motions are denied. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.