2:25-cv-00821
C.D. Cal.Feb 4, 2025Background
- Plaintiff Deondre Raglin, who is paraplegic, alleges the defendants failed to provide adequate parking facilities, violating the ADA and California’s Unruh Act.
- The Unruh Act claim is closely related to the federal ADA claim.
- The court has discretion to exercise or decline supplemental jurisdiction over the Unruh Act claim under 28 U.S.C. § 1367(c).
- Recent California legislative reforms led to a practice of plaintiffs filing ADA-based Unruh Act claims in federal court, avoiding state-court procedural requirements.
- The Ninth Circuit has recognized that this undermines state policy in discouraging predatory litigation by high-frequency ADA plaintiffs.
- The court issued an order to show cause why it should not dismiss the Unruh Act claim under § 1367(c)(4) for comity reasons, giving the plaintiff 14 days to respond.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court should retain supplemental jurisdiction over the Unruh Act claim | Raglin argues claims are related and should be heard together | Lin would argue state law issues dominate and federal court is improper | Court signals intent to decline jurisdiction at early stage for comity |
| Whether "exceptional circumstances" under § 1367(c)(4) apply | Raglin may argue circumstances are routine | Lin may argue the shift undermines state reforms | Court finds circumstances likely "exceptional" per Ninth Circuit |
| Whether procedural posture permits discretionary dismissal | Raglin may cite efficiency of joint adjudication | Lin may argue dismissal is timely and appropriate | Court notes early stage makes dismissal proper |
| Plaintiff’s status as a high-frequency litigant | Raglin to provide evidence on status | Lin may argue Plaintiff fits high-frequency definition | Court requires declaration to resolve this issue |
Key Cases Cited
- City of Chi. v. Int’l Coll. of Surgeons, 522 U.S. 156 (Supreme Court: District courts have discretion to decline supplemental jurisdiction)
- Arroyo v. Rosas, 19 F.4th 1202 (9th Cir.: Exceptional circumstances exist where retention of supplemental jurisdiction over Unruh Act claims undermines California legislative reforms)