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Jesus Garcia v. AM Imperial, LLC
2:23-cv-06258
C.D. Cal.
Dec 26, 2023
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Background

  • Jesus Garcia filed a federal lawsuit against AM Imperial, LLC, alleging violations of the ADA and several California state disability rights laws.
  • The complaint includes claims under the ADA, California's Unruh Civil Rights Act, California Disabled Persons Act, the California Health & Safety Code, and a negligence claim.
  • The court has original jurisdiction over the ADA claim and supplemental jurisdiction (through 28 U.S.C. § 1367) over the related state law claims.
  • California law imposes specific procedural requirements and enhanced pleading standards for certain construction-access claims, especially by “high-frequency litigants.”
  • The court issued an order demanding Garcia to justify why it should retain supplemental jurisdiction over the state law claims, requiring detailed information about the plaintiff's and counsel's litigation history and the damages sought.
  • Failure to respond adequately could result in the federal court declining jurisdiction over the state law claims and those claims being dismissed from the federal case.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the court should exercise supplemental jurisdiction over state law claims (Unruh Act, CDPA, etc.) Garcia contends state law claims are related to the ADA claim and fall under the court's supplemental jurisdiction. Not specified in this order. Court requires Garcia to show cause with detailed facts supporting supplemental jurisdiction or risk dismissal of state claims.
Whether requirements for high-frequency litigant status are satisfied Garcia must demonstrate compliance with heightened pleading and fee requirements. Not specified in this order. Plaintiff must specify litigant status and related facts as set by California law; failure to do so risks dismissal.
Adequacy of plaintiff’s pleading under California law Garcia argues the complaint meets all procedural and factual requirements for state law claims. Not specified. Court requires additional facts about the number of previous claims and nature of plaintiff's visits/intent.
Amount of statutory damages sought in state law claims Garcia to specify the exact amount of statutory damages sought under California law. Not specified. Plaintiff must state amount sought as part of response to order to show cause.

Key Cases Cited

  • City of Chicago v. Int’l Coll. of Surgeons, 522 U.S. 156 (1997) (clarifies that federal courts must weigh judicial economy, convenience, fairness, and comity when considering supplemental jurisdiction)
  • Carnegie-Mellon Univ. v. Cohill, 484 U.S. 343 (1988) (establishes factors for courts to consider in supplemental jurisdiction settings)
Read the full case

Case Details

Case Name: Jesus Garcia v. AM Imperial, LLC
Court Name: District Court, C.D. California
Date Published: Dec 26, 2023
Citation: 2:23-cv-06258
Docket Number: 2:23-cv-06258
Court Abbreviation: C.D. Cal.