Rebecca Castillo v. Zara USA, Inc.
2:25-cv-04773
C.D. Cal.Jun 2, 2025Background
- Plaintiff Rebecca Castillo filed a complaint against Zara USA, Inc., alleging violations of the Americans with Disabilities Act (ADA) and seeking damages under California's Unruh Civil Rights Act (Unruh Act).
- The complaint includes a request for injunctive relief under the ADA and damages under the Unruh Act, invoking supplemental jurisdiction under 28 U.S.C. § 1367.
- The litigation centers on alleged barriers to accessibility at a public accommodation operated by Zara, raising both federal and state law claims.
- California instituted heightened procedural and substantive requirements for construction-access claims under the Unruh Act, aiming to curb abusive litigation, including the need for verified complaints and additional fees for high-frequency litigants.
- The court is considering whether to exercise supplemental jurisdiction over the state law claims, as district courts have discretion to decline when state interests predominate or fairness/comity concerns arise.
- The court issued an Order to Show Cause requiring Castillo to justify why the court should retain jurisdiction over the Unruh Act claim, including disclosure of damages sought and high-frequency litigant status.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Should the court exercise supplemental jurisdiction over Unruh Act claim? | Castillo argues it is proper under § 1367 | Not specified in this order | Court has not yet decided; requires plaintiff to show cause |
| Applicability of California’s heightened Unruh Act standards in federal court | Asserts federal court should hear both claims | Not specified in this order | Court signals deference to state interests in Unruh Act enforcement |
| Requirement for verified complaint and high-frequency litigant status | Implied compliance | Not specified in this order | Plaintiff must declare and substantiate compliance |
| Potential dismissal for failure to comply or justify supplemental jurisdiction | Plaintiff must respond to avoid dismissal | Not specified in this order | Failure to comply may result in dismissal of state claims |
Key Cases Cited
- City of Chi. v. Int’l Coll. of Surgeons, 522 U.S. 156 (discussing discretionary doctrine of supplemental jurisdiction)
- Carnegie-Mellon Univ. v. Cohill, 484 U.S. 343 (articulating factors for exercising supplemental jurisdiction)
- Acri v. Varian Assocs., 114 F.3d 999 (recognizing district courts' discretion to decline supplemental jurisdiction)