2:24-cv-04455
C.D. Cal.Jun 13, 2024Background
- Plaintiff Miriam Maldonado filed a federal lawsuit alleging violations of the ADA and several California state laws regarding disability access.
- Defendants are San Bo Lau, LLC and unnamed Does.
- Maldonado asserts federal jurisdiction for the ADA claim and supplemental jurisdiction for related state law claims (Unruh Act, California Disabled Persons Act, Health & Safety Code, and negligence).
- California imposes heightened pleading standards and additional fee requirements for plaintiffs designated as "high-frequency litigants" in disability access cases.
- The court issued an Order to Show Cause requiring Maldonado to justify why the court should exercise supplemental jurisdiction over her state law claims.
- Maldonado must file a response within 14 days, detailing damages sought and providing information on her and her counsel’s litigation history regarding accessibility claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Should the court exercise supplemental jurisdiction over state law claims (Unruh, CDPA, H&S, negligence)? | Maldonado asserts pendant jurisdiction is proper for related state claims. | Not directly stated in order; implied challenge due to state standards and federal court suitability. | Court orders Maldonado to show cause; will decide after response. |
| Does Maldonado meet the "high-frequency litigant" criteria under California law? | Maldonado has not yet provided the required details. | Not addressed in current order. | Maldonado must submit declarations with specifics on litigation history. |
| What amount of statutory damages does Maldonado seek? | Not specified yet; to be detailed in response. | Not addressed in current order. | Maldonado must identify damages in her response. |
| Are state claims sufficiently pled according to California heightened standards? | Complaint filed; factual adequacy to be determined. | Not addressed in current order, but basis for court's scrutiny. | Court requires specifics as part of show cause response. |
Key Cases Cited
- City of Chicago v. Int’l Coll. of Surgeons, 522 U.S. 156 (1997) (federal courts should weigh judicial economy, convenience, fairness, and comity when deciding supplemental jurisdiction)
- Carnegie-Mellon Univ. v. Cohill, 484 U.S. 343 (1988) (articulates factors for discretionary exercise of supplemental jurisdiction)