Miriam Maldonado v. Ghassem Seyed Ghaderi
2:25-cv-04260
C.D. Cal.May 29, 2025Background
- Plaintiff filed a federal complaint seeking injunctive relief for an alleged violation of the Americans with Disabilities Act (ADA) and damages under California’s Unruh Act and other state law claims.
- The case is before the U.S. District Court with Judge Josephine L. Staton presiding.
- California law imposes heightened pleading requirements and fees for Unruh Act claims, especially targeting so-called “high-frequency litigants.”
- Plaintiffs sometimes file Unruh Act and ADA claims in federal court to avoid these stricter state law requirements.
- The judge has ordered the plaintiff to explain why the court should not decline supplemental jurisdiction over the state law (Unruh Act) claims under 28 U.S.C. § 1367(c).
- Plaintiff is required to specify damages sought and provide declarations establishing whether plaintiff or counsel qualify as "high-frequency litigants."
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court should exercise supplemental jurisdiction over Unruh Act/state claims | Likely to argue federal claim and state claim are related | Not present/not addressed | Plaintiff must show cause or court likely to decline jurisdiction over state law claims |
| Whether plaintiff (or counsel) qualifies as a "high-frequency litigant" | Plaintiff to submit declarations | Not present/not addressed | Plaintiff required to provide information or risk dismissal of supplemental state law claims |
| Whether claims for damages under Unruh Act are consistent with California's legislative intent | Plaintiff may argue entitlement under state law | Not present/not addressed | Court suggests that pursuing state damages in federal court undermines state law restrictions |
| Consequences of failing to respond to the court's order | N/A | N/A | Failure to respond may result in dismissal of entire action without prejudice |
Key Cases Cited
- City of Chicago v. Int’l Coll. of Surgeons, 522 U.S. 156 (1997) (discussing discretionary supplemental jurisdiction over related state law claims under federal question jurisdiction)
- Link v. Wabash R. Co., 370 U.S. 626 (1962) (district courts may dismiss cases for failure to comply with court orders under Rule 41(b))
- Hells Canyon Pres. Council v. U.S. Forest Serv., 403 F.3d 683 (9th Cir. 2005) (Rule 41(b) allows district courts to dismiss cases sua sponte for noncompliance)