Bryan Estrada v. Furr Paradise Hemet, LLC
5:22-cv-00185
| C.D. Cal. | Feb 1, 2022Background
- Plaintiff Bryan Estrada sued Furr Paradise Hemet, LLC and others alleging an ADA violation (injunctive relief), the California Unruh Civil Rights Act (damages), and additional state-law claims.
- Jurisdiction for the Unruh Act claim was asserted solely under supplemental jurisdiction (28 U.S.C. § 1367(a)).
- The Court noted it may decline supplemental jurisdiction under § 1367(c), citing Ninth Circuit concern that ADA-based Unruh claims can threaten federal-state comity.
- The Court emphasized its sua sponte obligation to confirm subject-matter jurisdiction.
- The Court ordered Plaintiff to show cause why the Court should exercise supplemental jurisdiction over the Unruh Act and other state claims, and to file declarations under penalty of perjury.
- The Court directed Plaintiff to state (1) the amount of Unruh statutory damages sought and (2) factual support whether Plaintiff or counsel are a “high-frequency litigant” under Cal. Code Civ. Proc. § 425.55; failure to timely/adequately respond by Feb. 15, 2022 could lead to dismissal or the Court declining supplemental jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Court should exercise supplemental jurisdiction over the Unruh Act and other state-law claims | Unruh claim arises from same facts as ADA claim and therefore can be heard under § 1367(a) | No responsive argument presented in the OSC; defendants did not defend exercise of supplemental jurisdiction in the order | Court ordered Plaintiff to show cause; signaled it may decline supplemental jurisdiction under § 1367(c) and Arroyo if concerns not addressed |
| Whether Plaintiff must specify the Unruh Act statutory damages sought | Plaintiff must disclose the amount sought (statutory damages) | Not asserted | Court ordered Plaintiff to state the amount sought in the response |
| Whether Plaintiff or counsel qualify as a “high-frequency litigant” under Cal. Code Civ. Proc. § 425.55 | Plaintiff must provide facts/declarations to allow the Court to determine high-frequency litigant status | Not asserted | Court ordered detailed, sworn factual declarations addressing high-frequency litigant status |
Key Cases Cited
- Nevada v. Bank of Am. Corp., 672 F.3d 661 (9th Cir. 2012) (district court may raise subject-matter jurisdiction sua sponte)
- Snell v. Cleveland, Inc., 316 F.3d 822 (9th Cir. 2002) (court may question jurisdiction at any time)