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Julio Cruz v. Golden Ox Burger
8:25-cv-00558
C.D. Cal.
Apr 14, 2025
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Background

  • 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)
Read the full case

Case Details

Case Name: Julio Cruz v. Golden Ox Burger
Court Name: District Court, C.D. California
Date Published: Apr 14, 2025
Docket Number: 8:25-cv-00558
Court Abbreviation: C.D. Cal.