Jardine Gougis v. LMS Electric, 2:25-cv-03781

Plaintiff filed suit alleging violations of the federal Americans with Disabilities Act (ADA), as well as California’s Unruh Act, Disabled Persons Act, Health & Safety Code, and a negligence claim.
The federal claim (ADA) provides original jurisdiction, while the state law claims are before the court on supplemental jurisdiction.
The court notes California has enacted heightened pleading requirements and additional filing restrictions for disability discrimination suits under the Unruh Act, especially for "high-frequency litigants."
California's measures, meant to deter vexatious and baseless accessibility claims, include special fees and more stringent pleading rules for plaintiffs (and attorneys) who repeatedly file such suits.
Filing state law claims in federal court can circumvent these California-specific restrictions, raising the question of whether federal courts should exercise supplemental jurisdiction over them.
The court issues an order to show cause, requiring plaintiff to justify why the court should retain jurisdiction over the California law claims and provide declarations regarding statutory damages and "high-frequency litigant" status.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether to exercise supplemental jurisdiction over state claims	Should retain jurisdiction	Should decline jurisdiction	Plaintiff ordered to show cause
Applicability of California's heightened requirements in federal	Should not limit federal claims	State restrictions should apply	Court considers state policy
Determination of high-frequency litigant status	Not addressed in order	Not addressed in order	Plaintiff must provide evidence
Consequences of no/inadequate response	Not applicable	Not applicable	Possible dismissal of state claims

City of Chicago v. Int’l Coll. of Surgeons, 522 U.S. 156 (1997) (sets forth factors courts may consider when deciding whether to exercise supplemental jurisdiction)
Link v. Wabash R. Co., 370 U.S. 626 (1962) (court may dismiss an action for failure to comply with court orders, even sua sponte)
Hells Canyon Pres. Council v. U.S. Forest Serv., 403 F.3d 683 (9th Cir. 2005) (Rule 41(b) dismissal may be initiated by the court)