Ramos v. Man de Yuan Enterprises, Inc., 2:24-cv-03348

Plaintiff Oscar Ramos sued Man de Yuan Enterprises, Inc. (d/b/a The Mandarin Restaurant) alleging ADA violations and three state-law disability-access claims (Cal. Health & Safety Code, Disabled Persons Act, Unruh Act).
Clerk entered default against Man de Yuan on March 31, 2025 after the company failed to appear; Ramos moved for default judgment on April 12, 2025 and the hearing was vacated and the motion taken under submission because the defendant did not oppose.
The court flagged whether to exercise supplemental jurisdiction over Ramos’s state-law claims under 28 U.S.C. § 1367, given California’s heightened procedural limits for construction-related accessibility claims.
The court reviewed Ramos’s prior filings and found he filed ten or more construction-related accessibility complaints in the prior 12 months, potentially qualifying him as a California “high-frequency litigant.”
Citing concerns about federal forum shopping that evades California’s filing and pleading restrictions, the court ordered Ramos to show cause within 14 days why the court should not decline supplemental jurisdiction and whether Doe defendants 1–50 will be dismissed.
The court warned that an inadequate response may result in a recommendation to dismiss the state-law claims without prejudice under § 1367(c) and that failure to respond could lead to recommending dismissal of the entire action.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court should exercise supplemental jurisdiction over state-law claims	Ramos implicitly seeks federal adjudication of state claims along with ADA claim	No response/failed to appear	Court ordered Ramos to show cause why it should not decline supplemental jurisdiction and warned dismissal without prejudice under §1367(c) is possible
Whether Ramos qualifies as a California "high-frequency litigant" subject to special filing/pleading limits	Ramos can contest the characterization or applicability of those limits	No response/failed to appear	Court found Ramos filed 10+ similar complaints in prior 12 months and directed him to address the issue in the show-cause filing
Status of default judgment motion against Man de Yuan	Ramos seeks default judgment for alleged violations	Man de Yuan did not oppose or appear	Hearing vacated and motion taken under submission; court signaled state claims may be dismissed without prejudice pending the show-cause response
Whether Doe Defendants 1–50 should remain	Ramos has not sought default against Does or served them	No response/failed to appear	Court ordered Ramos to state whether Does will be dismissed as part of his show-cause response

Arroyo v. Rosas, 19 F.4th 1202 (9th Cir. 2021) (California enacted procedural limits to curb high-frequency Unruh Act plaintiffs and limit state-law damages claims)
Vo v. Choi, 49 F.4th 1167 (9th Cir. 2022) (district courts may decline supplemental jurisdiction to prevent circumvention of California’s procedural requirements)