Raul Uriarte-Limon v. Star Buffet Lynwood Inc
2:24-cv-10324
| C.D. Cal. | Dec 10, 2024Background
- Plaintiff filed a complaint alleging violation of the federal Americans with Disabilities Act (ADA) and seeking damages under California’s Unruh Act.
- The ADA claim provides federal jurisdiction; the Unruh Act claim is attached as a state law claim for damages.
- California law imposes heightened pleading and filing requirements for Unruh Act claims involving construction-related accessibility issues, particularly targeting "high-frequency litigants" (plaintiffs or attorneys filing 10+ such cases in the past 12 months).
- Plaintiffs filing in federal court may avoid these California-specific restrictions and fees, which has led to concerns about forum-shopping.
- The Court issued an Order to Show Cause, requiring Plaintiff to explain why the federal court should exercise supplemental jurisdiction over the state claim and to declare the amount of damages and high-frequency litigant status.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether to exercise supplemental jurisdiction over Unruh Act | Likely to argue for federal court | Argues California courts intended | Court requires Plaintiff to show cause why |
| claim, given California's heightened requirements | jurisdiction to recover damages | for limits to apply to such cases | it should not decline jurisdiction |
| Must Plaintiff disclose damages and high-frequency status? | Likely to comply/argue not "high" | N/A | Plaintiff ordered to provide declarations |
| Possible dismissal for failing to comply with court order | Plaintiff to respond to avoid this | N/A | Failure to comply may result in dismissal |
Key Cases Cited
- City of Chicago v. Int’l Coll. of Surgeons, 522 U.S. 156 (outlines factors for federal court’s exercise of supplemental jurisdiction)
- Link v. Wabash R. Co., 370 U.S. 626 (district courts can sua sponte dismiss for failure to comply with court orders)
- Hells Canyon Pres. Council v. U.S. Forest Serv., 403 F.3d 683 (recognizes court’s power to dismiss claims sua sponte for failure to comply)
