5:25-cv-02017
C.D. Cal.Aug 13, 2025Background
- Plaintiff Deondre Raglin filed suit in the Central District of California, alleging violations of the Americans with Disabilities Act (ADA) and California's Unruh Civil Rights Act (Unruh Act), with all state claims relying on supplemental jurisdiction.
- California has imposed heightened pleading requirements and additional fees for "high-frequency litigants"—those who bring numerous accessibility claims—under the Unruh Act.
- The complaint reveals the plaintiff filed over ten federal construction-related accessibility lawsuits in the year prior, qualifying him as a probable high-frequency litigant by California standards.
- Federal courts in California frequently decline to exercise supplemental jurisdiction over such claims, in order to prevent plaintiffs from circumventing these state requirements by filing in federal court.
- The court has issued an Order to Show Cause, requiring the plaintiff to justify why the court should retain supplemental jurisdiction over the state claims and to disclose requested statutory damages and his litigant status.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether to exercise supplemental jurisdiction over state-law claims | Not yet presented; will respond to OSC | Not yet presented; may respond to OSC | Court orders plaintiff to show cause why it should retain jurisdiction |
| Qualification as a high-frequency litigant | Not yet presented | Not yet presented | Plaintiff ordered to declare litigant status |
| Statutory damages sought | To be disclosed per OSC | N/A | Plaintiff must specify damages demanded |
| Impact of state reforms on federal litigation | N/A | N/A | Court cites state interest—leans toward declining jurisdiction |
Key Cases Cited
- United Mine Workers v. Gibbs, 383 U.S. 715 (1966) (establishing supplemental jurisdiction as discretionary, emphasizing judicial economy, convenience, fairness, and comity)
- Nishimoto v. Federman-Bachrach & Assocs., 903 F.2d 709 (9th Cir. 1990) (district courts must continually consider judicial economy, convenience, fairness, and comity in retaining state law claims)