Adam Ghadiri v. Orange County Scaffold, Inc., 8:21-cv-00485

Plaintiff’s complaint asserts federal ADA injunctive relief, California Unruh Act damages, and other state-law claims.
Court issued an in-chambers Order to Show Cause whether it should decline supplemental jurisdiction over the Unruh Act and other state claims under 28 U.S.C. § 1367(c).
California law (since 2012) imposes heightened pleading requirements and limits for "construction-related accessibility" claims and special rules/fees for "high-frequency litigants" (10+ such complaints in 12 months), which also apply to attorneys.
The Court noted a policy concern that filing state statutory-damage claims in federal court can evade California’s procedural and financial limits.
The Court gave Plaintiff 10 days to show cause and ordered Plaintiff to (1) identify the amount of statutory damages sought and (2) submit declarations under penalty of perjury from Plaintiff and counsel with facts necessary to determine whether each is a high-frequency litigant.
The Order warns that failure to respond may lead to dismissal of the entire action under Fed. R. Civ. P. 41(b), and that an inadequate response will result in the Court declining supplemental jurisdiction and dismissing the state claims under § 1367(c).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court should exercise supplemental jurisdiction over Unruh Act and other state-law claims	Plaintiff seeks to retain Unruh and state claims in federal court (implicit)	No argument on record; Court is concerned federal forum circumvents California restrictions	Court ordered Plaintiff to show cause why the Court should not decline supplemental jurisdiction and to supply further information; discretion to dismiss exists under §1367(c)
Whether Plaintiff or counsel are “high-frequency litigants” subject to special rules	Plaintiff must demonstrate they are not high-frequency litigants (or disclose status)	N/A	Plaintiff must submit declarations under penalty of perjury with facts to allow the Court to determine high-frequency litigant status
Whether failure to comply warrants dismissal	Plaintiff likely argues for preservation of claims by compliance	N/A	Failure to timely/respond may lead to dismissal of the entire action under Rule 41(b); inadequate response will lead to dismissal of state claims under §1367(c)

City of Chicago v. Int’l Coll. of Surgeons, 522 U.S. 156 (1997) (discretionary factors and considerations for declining supplemental jurisdiction)
Link v. Wabash R. Co., 370 U.S. 626 (1962) (district court may dismiss an action sua sponte for failure to prosecute or comply with orders)
Hells Canyon Pres. Council v. U.S. Forest Serv., 403 F.3d 683 (9th Cir. 2005) (discussing dismissal for failure to comply with court orders)