Bernard Taruc v. Auto Collision Group Covina Inc
2:25-cv-04519
C.D. Cal.Jun 10, 2025Background
- Plaintiff Bernard Taruc, who uses a wheelchair, sued Auto Collision Group Covina Inc. and related parties after visiting their business and encountering inadequate disability parking and related barriers.
- Taruc alleges the business did not provide accessible parking, signage, or van accessibility, denying him full and equal access, and deterring future visits.
- The complaint included one federal ADA claim for injunctive relief and four state law claims (Unruh Act, California Disabled Persons Act, California Health and Safety Code, and negligence) seeking both damages and injunctive relief.
- Taruc and his counsel admitted they meet California's “high-frequency litigant” definition, but did not fully comply with the state’s heightened pleading standards required for such litigants.
- The federal court ordered Taruc to show why it should exercise supplemental jurisdiction over his state claims, considering California’s intent to limit Unruh Act litigation abuses by high-frequency litigants.
- The court ultimately declined supplemental jurisdiction over Taruc’s state claims because of predominance of state law issues, legislative interests, and comity concerns.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether supplemental jurisdiction over state law claims should be exercised by the federal court | Taruc argues there is no unique burden in federal court compared to state court procedures | Not detailed (defendants did not appear yet) | Court declines supplemental jurisdiction over state law claims, citing predominance, comity, and exceptional circumstances |
| Whether Taruc qualifies as a "high-frequency litigant" under California law | Taruc admits he qualifies | Not stated (not present in record) | Court finds Taruc qualifies and did not comply with related heightened pleading standards |
| Whether state law claims predominate over the ADA claim | Taruc argues for adjudication of all claims | Not detailed | Court finds state law claims (which provide for monetary damages) predominate over the single ADA injunctive claim |
| Whether exceptional circumstances justify declining supplemental jurisdiction | Taruc argues there is nothing unique about state court procedure | Not detailed | Court finds Ninth Circuit precedent establishes exceptional circumstances due to legislative framework and comity concerns |
Key Cases Cited
- City of Chicago v. Int’l Coll. of Surgeons, 522 U.S. 156 (federal courts must consider judicial economy, convenience, fairness, and comity in exercising supplemental jurisdiction)
- United Mine Workers of Am. v. Gibbs, 383 U.S. 715 (permits district courts to dismiss state claims if they substantially predominate over federal claims)
- Molski v. M.J. Cable, Inc., 481 F.3d 724 (Unruh Act allows statutory damages without proof of actual damages)
- Wander v. Kaus, 304 F.3d 856 (ADA provides only for injunctive relief in private lawsuits)