Federal Court Has No Jurisdiction Over Claim That Municipal Ordinance Preempted by State Law

In Lone Star Security & Video v. City of Los Angeles, published today, the 9th Circuit holds that a federal district court does not have jurisdiction over a 42 USC section 1983 due process claim that merely alleges that a local ordinance is preempted by state law.  Such a contention does not state a non-frivolous claim under either substantive due process or procedural due process; and merely brings a state law dispute into federal court.