Juan Valencia v. Jesse's Auto Mall
2:25-cv-06477
| C.D. Cal. | Jul 21, 2025Background
- The case involves Juan Valencia suing Jesse's Auto Mall under the Americans with Disabilities Act (ADA) and asserting related state law claims.
- The suit alleges the existence of ADA-accessibility barriers at the defendant’s premises.
- The Court emphasizes its policy of encouraging the expedient resolution of ADA cases, particularly where alleged barriers have been remediated before trial.
- The Court orders both parties to submit a joint status report regarding remedial measures taken and their positions on those measures; both are to state intentions for summary judgment.
- The plaintiff has invoked supplemental jurisdiction for state law claims, specifically the Unruh Act, triggering additional scrutiny.
- The Court orders Valencia to show cause as to why the Court should retain supplemental jurisdiction and to specify damages sought, with further required factual declarations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ADA claim is moot if alleged barriers are remediated | Barriers still in dispute or damages warranted | Barriers have been removed, so claim is moot | ADA claim is moot if barriers are removed and not likely to recur |
| Entitlement to nominal damages under Title III of the ADA | Plaintiff entitled to nominal damages | Not permitted under ADA | Nominal damages are not available under Title III |
| Court’s discretion to retain supplemental jurisdiction | Seeks court's exercise over state claim | Prefer dismissal if ADA claim is moot | Court may decline jurisdiction if ADA claim is dismissed as moot |
| Eligibility for attorney's fees if case is mooted pre-trial | Plaintiff should recover fees | No fees warranted if case is moot | No attorney’s fees if ADA claim is mooted before trial |
Key Cases Cited
- Oliver v. Ralphs Grocery Co., 654 F.3d 903 (9th Cir. 2011) (ADA claims may be dismissed as moot if barriers are remediated and not likely to recur)
- Am. Cargo Transp., Inc. v. United States, 625 F.3d 1176 (9th Cir. 2010) (Court can dismiss moot claims and decide supplemental jurisdiction)
- Buckhannon Bd. & Care Home, Inc. v. W. Va. Dept. of Health & Human Resources, 532 U.S. 598 (2001) (No attorney's fees may be awarded if plaintiff is not a prevailing party due to mootness)