Robert Cauley v. California Tactical Firearms LLC, 2:25-cv-01152

Plaintiff Robert Cauley, a wheelchair user, brought suit against California Tactical Firearms, alleging physical barriers at their facilities in violation of the ADA and the Unruh Act.
The ADA claim creates federal question jurisdiction, and the Unruh Act claim is before the court via supplemental jurisdiction.
The Unruh Act, as amended by California in 2012 and 2015, was meant to discourage abusive litigation by frequent plaintiffs in disability cases by creating additional state-law requirements.
Since those amendments, there has been a shift in such cases being filed in federal court to avoid state requirements, undermining California's legislative goals.
The Ninth Circuit in Arroyo v. Rosas recognized that these circumstances present an “exceptional” situation justifying declination of supplemental jurisdiction over Unruh Act claims in federal court under 28 U.S.C. § 1367(c)(4).
The current case is at an early stage, and the Court has not yet addressed the merits; the court orders plaintiff to show cause why the Unruh Act claim should not be dismissed without prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether court should exercise supplemental jurisdiction over the Unruh Act claim given comity concerns under § 1367(c)(4)	Plaintiff should have his Unruh Act claim heard alongside ADA claim in federal court	Allowing Unruh Act claims in federal court undermines state reforms	Court intends to decline jurisdiction and orders plaintiff to justify retention
Impact of timing on supplemental jurisdiction decisions (i.e., early vs. late in the case)	Not directly addressed in the order	Not directly addressed	Early-stage case supports declining jurisdiction (per Arroyo guidance)
Plaintiff’s status as a high-frequency litigant under state law	Not addressed yet; required to provide info	Not addressed in the order	Court requires declarations to determine if plaintiff/counsel qualify
Dismissal of Unruh Act claim without prejudice	Unstated, will be addressed in response	Unstated, will be addressed if necessary	If no timely response, claim dismissed without prejudice

City of Chicago v. Int’l College of Surgeons, 522 U.S. 156 (discussing discretionary nature of supplemental jurisdiction)
Arroyo v. Rosas, 19 F.4th 1202 (9th Cir. 2021) (holding federal courts may decline supplemental jurisdiction over Unruh Act claims to protect California’s state law interests)