Sam Benford v. York Smoke Shop
2:24-cv-10043
C.D. Cal.Nov 27, 2024Background
- Plaintiff filed a complaint alleging violations of the Americans with Disabilities Act (ADA) and sought injunctive relief.
- Plaintiff also brought claims under California’s Unruh Act, Disabled Persons Act, Health & Safety Code, and a general negligence claim, seeking damages.
- The case is in federal court because of the federal ADA claim, but the state law claims are based on supplemental jurisdiction.
- California has enacted heightened pleading and filing requirements for "construction-related accessibility claims" (including state law disability claims) to deter frivolous lawsuits and manage litigation burdens on businesses.
- There are further restrictions applied to "high-frequency litigants," including special fees and pleading standards under state law.
- The Court is considering whether to decline supplemental jurisdiction over the state law claims to avoid allowing plaintiffs to circumvent these heightened state requirements by filing in federal court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether to retain supplemental jurisdiction over state law disability and negligence claims under 28 U.S.C. § 1367(c) | Plaintiff will argue these are properly related and should be heard together | Defendant not present/argument not stated but implied that state law claims evade state reforms | Court questions whether to retain jurisdiction, considering CA's heightened standards; Orders Plaintiff to show cause why it should not decline jurisdiction |
| Whether Plaintiff is a high-frequency litigant under CA law | Plaintiff ordered to declare their status | Not addressed | Court orders Plaintiff to provide info to determine status |
| Amount of statutory damages sought by Plaintiff | Plaintiff to specify | Not addressed | Court orders Plaintiff to provide this information |
| Consequence of inadequate response | N/A | N/A | Dismissal of state law claims or possibly entire action |
Key Cases Cited
- City of Chicago v. Int’l Coll. of Surgeons, 522 U.S. 156 (1997) (establishes that district courts have discretion to decline supplemental jurisdiction over state law claims)
- Link v. Wabash R. Co., 370 U.S. 626 (1962) (district courts may sua sponte dismiss cases if parties fail to comply with court orders)
- Hells Canyon Pres. Council v. U.S. Forest Serv., 403 F.3d 683 (9th Cir. 2005) (dismissal under Rule 41(b) applies to failure to prosecute or comply with court orders)