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