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Deondre Raglin v. Gabriela Guzman
2:24-cv-09944
C.D. Cal.
Nov 21, 2024
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Background

  • Plaintiff filed a federal claim for injunctive relief under the Americans with Disabilities Act (ADA) and state claims for damages under California’s Unruh Act and other state laws.
  • California made it harder to file disability discrimination lawsuits under the Unruh Act by imposing stricter pleading standards and higher filing fees, especially on repeat ("high-frequency") litigants.
  • The state’s new requirements are designed to limit excessive damages claims and curb abusive litigation practices.
  • Federal courts have the discretion to exercise supplemental jurisdiction over related state law claims but may choose to decline it, particularly where state interests are implicated.
  • The court questioned whether it should keep jurisdiction over the Unruh Act and related state claims, and ordered Plaintiff to justify why it should.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Should the court exercise supplemental jurisdiction over Unruh Act and related state-law claims? Likely argues for keeping state claims in court to obtain damages and comprehensive relief. State not present, but court notes California wants to limit such suits in its courts. Plaintiff ordered to show cause why jurisdiction should be retained; risk of dismissal if not justified.

Key Cases Cited

  • City of Chicago v. Int’l Coll. of Surgeons, 522 U.S. 156 (discussing federal courts’ discretion to decline supplemental jurisdiction over state law claims)
  • Link v. Wabash R. Co., 370 U.S. 626 (upholding court’s authority to dismiss actions sua sponte for failure to comply with orders)
  • Hells Canyon Pres. Council v. U.S. Forest Serv., 403 F.3d 683 (recognizing district court’s power to dismiss claims under its inherent authority)
Read the full case

Case Details

Case Name: Deondre Raglin v. Gabriela Guzman
Court Name: District Court, C.D. California
Date Published: Nov 21, 2024
Docket Number: 2:24-cv-09944
Court Abbreviation: C.D. Cal.