5:25-cv-02047
C.D. Cal.Aug 12, 2025Background
- Plaintiff Deondre Raglin sued KB Barstow Cinema LLC alleging violations of the Americans with Disabilities Act (ADA) and seeking damages under California’s Unruh Civil Rights Act (Unruh Act).
- The federal claim concerns injunctive relief under the ADA, while the state law claim seeks damages for discrimination under the Unruh Act.
- Plaintiff asked the federal court to exercise supplemental jurisdiction over the Unruh Act claim (i.e., to hear the state law claims as part of the federal case).
- California has heightened its pleading requirements and imposed additional fees for “high-frequency litigants” under the Unruh Act to curb abusive disability claims.
- The court issued an order to show cause (OSC), requiring Plaintiff to explain why the court should retain jurisdiction over the Unruh Act claim, highlighting judicial discretion to decline supplemental jurisdiction.
- Plaintiff is directed to provide information about statutory damages sought and whether they meet the definition of a high-frequency litigant.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held (Current Stage) |
|---|---|---|---|
| Should the court exercise supplemental jurisdiction over Unruh? | Unruh claim related to ADA; should be heard | Not present/Not provided | OSC issued: Plaintiff must justify supplemental jurisdiction; undecided |
| Application of high-frequency litigant requirements | Not yet stated | Not present/Not provided | Plaintiff ordered to address and file declarations |
Key Cases Cited
- City of Chi. v. Int’l Coll. of Surgeons, 522 U.S. 156 (discretionary nature of supplemental jurisdiction by federal courts)
- Carnegie-Mellon Univ. v. Cohill, 484 U.S. 343 (factors courts consider when deciding supplemental jurisdiction)
- Acri v. Varian Assocs., 114 F.3d 999 (Ninth Circuit recognizing courts' discretion to decline supplemental jurisdiction)