2:25-cv-03775
C.D. Cal.May 28, 2025Background
- Plaintiff Moises Villalobos filed suit in federal court alleging violations of the Americans with Disabilities Act (ADA) and seeking damages under California’s Unruh Civil Rights Act (Unruh Act).
- The plaintiff requested the federal court exercise supplemental jurisdiction over the state law Unruh Act claim under 28 U.S.C. § 1367.
- The court notes that supplemental jurisdiction is discretionary and not automatic, and such claims may be declined in certain circumstances.
- California has enacted stricter pleading and filing requirements for construction-related accessibility claims to prevent abuse and excessive litigation, including verified complaints and extra fees for high-frequency litigants.
- The court identifies an increasing trend of federal courts declining supplemental jurisdiction over Unruh Act claims, particularly due to concerns of comity and to respect California's rules aimed at curbing frivolous disability litigation.
- The court orders plaintiff to show cause in writing why supplemental jurisdiction should be exercised, and to detail statutory damages sought and whether plaintiff qualifies as a high-frequency litigant.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Should the court exercise supplemental jurisdiction over the Unruh Act claim? | Villalobos requests the court retain supplemental jurisdiction to hear the state claim alongside the federal ADA claim. | Rodriguez likely argues the court should decline jurisdiction due to California's unique procedures and public policy aims. | The court has not yet ruled; it requires plaintiff to show cause as to why jurisdiction should be exercised. |
Key Cases Cited
- City of Chi. v. Int’l Coll. of Surgeons, 522 U.S. 156 (U.S. 1997) (discusses the discretionary nature of supplemental jurisdiction under § 1367 and its limitations)
- Carnegie-Mellon Univ. v. Cohill, 484 U.S. 343 (U.S. 1988) (discretion factors for federal courts considering supplemental jurisdiction)
- Acri v. Varian Assocs., 114 F.3d 999 (9th Cir. 1997) (recognizes courts' discretion to decline supplemental jurisdiction under § 1367)