Robert Mena v. Ofelia Jauregui, 8:24-cv-02451

Plaintiff Robert Mena filed a federal complaint alleging violations of the Americans with Disabilities Act (ADA), the Unruh Civil Rights Act, and other California laws against defendants, based on construction-related accessibility issues.
The federal claim arises under the ADA and state claims are brought through supplemental jurisdiction under 28 U.S.C. § 1367.
Recent California legislation imposes heightened pleading standards and special fees for "high-frequency litigants"—plaintiffs who have filed large numbers of accessibility lawsuits—when pursuing Unruh Act claims in state court.
The Court noted that Mena has filed over ten construction-related accessibility cases in the past year and would be considered a high-frequency litigant under California law.
The Court raised concerns that exercising supplemental jurisdiction over the state-law claims would allow plaintiffs like Mena to evade California's stricter requirements by proceeding in federal court.
The Court ordered Mena to show cause why it should not decline supplemental jurisdiction over the state-law claims and required specific information and declarations to be filed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court should exercise supplemental jurisdiction over state-law Unruh Act claims given California's recent reforms for high-frequency litigants	Mena likely argues federal court is appropriate, and supplemental jurisdiction is proper given the relatedness to ADA claims	Not yet presented	Court is considering declining supplemental jurisdiction and orders Mena to show cause

United Mine Workers v. Gibbs, 383 U.S. 715 (Supreme Court established supplemental jurisdiction is discretionary, to be informed by fairness, economy, and comity)
Nishimoto v. Federman-Bachrach & Assocs., 903 F.2d 709 (9th Cir. described the court's discretion in exercising supplemental jurisdiction)