Jardine Gougis v. David Morales, 2:25-cv-05749

Plaintiff Jardine Gougis filed a complaint in federal court alleging violations of the Americans with Disabilities Act (ADA), the Unruh Civil Rights Act, and related California laws.
Federal jurisdiction over ADA claims is clear, but Gougis’ state-law claims are before the court under supplemental jurisdiction.
California law imposes special requirements and fees for high-frequency litigants (those filing many accessibility lawsuits), aiming to prevent abuse.
The court reviewed Gougis’ litigation history and found he filed over ten similar accessibility cases in the past year, qualifying him as a high-frequency litigant under California law.
The court is concerned that exercising supplemental jurisdiction over state law claims could allow such plaintiffs to avoid California’s stricter requirements.
The court orders Gougis to show cause why it should not decline supplemental jurisdiction over the state-law claims, requiring both evidence regarding his litigant status and a statement of claimed damages.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Should the court exercise supplemental jurisdiction over state-law claims by a high-frequency litigant?	Gougis may argue it is judicially efficient and fair for federal court to consider all claims together.	Defendants often argue that state court is the appropriate forum where stricter state requirements apply.	Court orders Gougis to show cause why it should exercise such jurisdiction and signals possible declination.
Does federal court jurisdiction allow plaintiffs to bypass California’s heightened requirements for Unruh Act claims?	Gougis may contend federal statutes permit parallel federal and state enforcement.	Defendants may argue federal jurisdiction could undermine state policy intended to curtail excessive litigation.	Court expresses concern over forum-shopping and possible evasion of state reforms.
Is Gougis a “high-frequency litigant” under California law?	Plaintiff has not yet provided evidence or declaration regarding status.	Defendants may cite public records and previous filings confirming high-frequency status.	Court finds docket shows more than ten similar actions, preliminarily qualifying Gougis.
What are the necessary steps if the court declines supplemental jurisdiction?	Gougis may seek to keep state claims joined to avoid multiple lawsuits.	Defendants may prefer dismissal for procedural and strategic reasons.	Court may dismiss state-law claims without prejudice if it declines jurisdiction.

United Mine Workers v. Gibbs, 383 U.S. 715 (federal courts' discretion in exercising supplemental jurisdiction over state-law claims)
Nishimoto v. Federman-Bachrach & Assocs., 903 F.2d 709 (setting standards for exercising supplemental jurisdiction in light of judicial economy, convenience, fairness, and comity)