Julio Cruz v. Golden Ox Burger
8:25-cv-00558
C.D. Cal.Apr 14, 2025Background
- Plaintiff Julio Cruz alleges violations concerning disability access at Golden Ox Burger, including claims under the Americans with Disabilities Act (ADA) and California's Unruh Civil Rights Act (Unruh Act).
- The federal claim is for injunctive relief under the ADA, while the state claim seeks damages pursuant to the Unruh Act.
- Plaintiff has requested the federal court exercise supplemental jurisdiction over the state law claim under 28 U.S.C. § 1367.
- California has enacted heightened pleading standards and a special filing fee for frequent Unruh Act plaintiffs to curb abusive litigation.
- Central District of California courts often decline supplemental jurisdiction over Unruh Act claims to respect California's regulatory interests and anti-abuse measures.
- The court issued an order for Plaintiff to justify why the court should exercise supplemental jurisdiction, focusing on whether they are a high-frequency litigant and the amount of statutory damages sought.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Should the court exercise supplemental jurisdiction over the Unruh Act claim? | Federal courts can hear related state claims for efficiency. | State interests and anti-abuse measures warrant keeping Unruh claims in state court. | Court has not yet ruled; plaintiff must show cause. |
| Whether the Unruh Act claim is subject to heightened state standards. | Plaintiff may argue compliance or that federal forum should apply federal standards. | Defendants assert that state standards are designed to deter abuse, and federal courts should respect them. | Court signals deference to state rules; requires more information. |
| Whether plaintiff qualifies as a high-frequency litigant under California law. | Plaintiff may claim not to be high-frequency or otherwise provide justification. | Defendant likely insists on state vetting of frequent filers. | Court orders declarations on litigant status. |
| Whether comity and fairness favor declining supplemental jurisdiction. | Plaintiff may argue efficiency and fairness in federal forum. | Defendant stresses comity and California's regulatory interest. | Court seriously considers declining jurisdiction as other courts have. |
Key Cases Cited
- City of Chi. v. Int'l Coll. of Surgeons, 522 U.S. 156 (district courts have discretion in deciding supplemental jurisdiction)
- Carnegie-Mellon Univ. v. Cohill, 484 U.S. 343 (factors for exercising or declining supplemental jurisdiction)
- Acri v. Varian Assocs., 114 F.3d 999 (discretionary nature of supplemental jurisdiction in federal courts)
