Juan Valencia v. Best California Gas, LTD
2:24-cv-10276
C.D. Cal.Dec 2, 2024Background
- Plaintiff Juan Valencia filed a lawsuit against Best California Gas, Ltd. and others, alleging violations under the Americans with Disabilities Act (ADA), Unruh Civil Rights Act, and various state laws.
- The plaintiff seeks injunctive relief for ADA violations and damages under the Unruh Act.
- The federal court's jurisdiction over the Unruh Act claim is based on supplemental jurisdiction per 28 U.S.C. § 1367(a).
- The court noted it might decline supplemental jurisdiction under § 1367(c) due to concerns about federal-state comity, especially with lawsuits allegedly circumventing California’s state law reform.
- The court issued an Order to Show Cause, requiring plaintiff to justify why supplemental jurisdiction should be exercised for the state law claims.
- Plaintiff is directed to submit evidence on damages sought under the Unruh Act and whether plaintiff or counsel is a "high-frequency litigant" by December 16, 2024, or risk dismissal of those claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Should the court exercise supplemental jurisdiction over Unruh Act and state law claims? | Valencia seeks to have both federal and state law claims heard together for efficiency and complete relief. | Defendants (practices/motives not specified but likely challenge supplemental jurisdiction due to abuse concerns). | No decision yet; plaintiff must show cause why jurisdiction should be retained. |
| Whether plaintiff/counsel is a "high-frequency litigant." | Valencia has not yet responded; court demands disclosure. | Defendants' position not stated. | Plaintiff must provide facts in declaration. |
Key Cases Cited
- Arroyo v. Rosas, 19 F.4th 1202 (9th Cir. 2021) (establishes district courts may decline supplemental jurisdiction over Unruh Act claims in ADA cases to respect state reforms and jurisdictional comity)
- Nevada v. Bank of Am. Corp., 672 F.3d 661 (9th Cir. 2012) (court may raise subject matter jurisdiction sua sponte at any time)
- Snell v. Cleveland, Inc., 316 F.3d 822 (9th Cir. 2002) (supports court’s independent responsibility to assess jurisdiction)