2:25-cv-06483
C.D. Cal.Jul 24, 2025Background
- Plaintiff Ana Ventura filed a complaint against Partybake Insighters, Inc. and others alleging violations of the Americans with Disabilities Act (ADA) and related California laws, including the Unruh Civil Rights Act.
- Plaintiff's state law claims are before the federal court under supplemental jurisdiction, as the ADA provides the basis for original federal jurisdiction.
- California has enacted specific procedural requirements and additional filing fees for high-frequency litigants bringing construction-related accessibility claims under the Unruh Act in state court.
- Plaintiff has filed more than ten similar accessibility actions in federal court within the preceding year, which would classify her as a high-frequency litigant under California law.
- The Court is concerned that exercising supplemental jurisdiction over these state law claims could allow plaintiffs to evade California's stricter requirements by filing in federal court.
- The Court has ordered both parties to show cause why it should not decline supplemental jurisdiction over the state law claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Court should exercise supplemental jurisdiction over state law accessibility claims brought by a high-frequency litigant | Not stated yet (Plaintiff to respond) | Not stated yet (Defendant to respond) | Court has not ruled; ordered parties to show cause |
Key Cases Cited
- United Mine Workers v. Gibbs, 383 U.S. 715 (Supreme Court articulates discretion to exercise supplemental jurisdiction and relevant factors)
- Nishimoto v. Federman-Bachrach & Assocs., 903 F.2d 709 (9th Cir. describes factors for exercising supplemental jurisdiction)