Schutza v. Cuddeback
262 F. Supp. 3d 1025
| S.D. Cal. | 2017Background
- Plaintiff Scott Schutza, a paraplegic wheelchair user, sued owners/operators of TrailersPlus alleging ADA and California Unruh Act access violations after encountering multiple architectural barriers.
- Complaint alleges at least nine distinct accessibility defects (entrance threshold, parking, counters, restroom doorway, grab bars, sink knee clearance, mirror height, etc.).
- Plaintiff seeks injunctive relief under the ADA and statutory/treble monetary damages under the Unruh Act (minimum $4,000 per offense).
- Defendants moved to dismiss the Unruh Act claim under 28 U.S.C. § 1367(c); plaintiff did not oppose the motion.
- Court retained the ADA claim but granted dismissal of the Unruh Act claim, finding reasons to decline supplemental jurisdiction: (1) Unruh claim substantially predominates; (2) exceptional circumstances (comity and discouraging forum-shopping) compell dismissal.
- The court emphasized California’s heightened pleading rules for frequent disability litigants and noted Schutza’s extensive filing history (over 100 cases, numerous settlements), which supported concerns about end-running state requirements.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether to exercise supplemental jurisdiction over the Unruh Act claim under 28 U.S.C. § 1367(c) | Schutza pursued concurrent federal ADA injunctive relief and state Unruh damages; impliedly that federal court may hear both claims | Defendants argued § 1367(c) permits declining jurisdiction because the Unruh claim raises state-law issues, substantially predominates (statutory damages), and plaintiff is forum-shopping to avoid state pleading rules | Court declined supplemental jurisdiction and dismissed the Unruh Act claim under § 1367(c) (retained ADA claim) |
| Whether the Unruh Act claim substantially predominates over the ADA claim | Schutza alleged multiple violations supporting injunctive relief and Unruh damages | Defendants: multiple discrete alleged violations produce large statutory damages (minimum $4,000 each) so state damages predominate over federal injunctive relief | Held: Unruh claim substantially predominates (statutory minimums could total tens of thousands) |
| Whether comity and California’s pleading rules justify declining jurisdiction | Schutza proceeded in federal court despite state rules; plaintiff did not oppose motion | Defendants argued comity and avoiding enforcement of California’s heightened pleading requirements for frequent litigants justify dismissal | Held: exceptional circumstances exist (comity + discouraging forum-shopping); court declined jurisdiction on that basis |
| Whether plaintiff’s litigation history constitutes forum-shopping warranting dismissal | Schutza alleged many prior disability suits and settlements; plaintiff offered no opposition | Defendants argued Schutza is a high-frequency litigant using federal forum to evade state rules | Held: court found plaintiff’s history (over 100 cases, many settlements) supported conclusion of forum-shopping and was a compelling reason to decline jurisdiction |
Key Cases Cited
- United Mine Workers v. Gibbs, 383 U.S. 715 (establishes supplemental jurisdiction considerations: judicial economy, convenience, fairness, comity)
- San Pedro Hotel Co. v. City of Los Angeles, 159 F.3d 470 (9th Cir.) (court may decline supplemental jurisdiction under any § 1367(c) provision without detailed explanation)
- Exec. Software N. Am., Inc. v. U.S. District Court, 24 F.3d 1545 (9th Cir.) (requires articulation when declining jurisdiction under § 1367(c)(4) and weighing judicial values)
- Molski v. M.J. Cable, Inc., 481 F.3d 724 (9th Cir.) (ADA/Unruh relationship; Unruh damages do not require proof of actual damages)
- Lentini v. California Center for the Arts, Escondido, 370 F.3d 837 (9th Cir.) (no showing of intent required for ADA violations)
- Wander v. Kaus, 304 F.3d 856 (9th Cir.) (ADA remedies limited to injunctive relief, not damages)
- Munson v. Del Taco, Inc., 46 Cal.4th 661 (Cal.) (violation of ADA can constitute Unruh Act violation; relationship between federal and state claims)
- Botosan v. Paul McNally Realty, 216 F.3d 827 (9th Cir.) (Unruh statutory damages can be awarded absent proof of actual damages)
- Brick Oven Restaurant v. Organization for Advancement of Minorities, 406 F. Supp. 2d 1120 (S.D. Cal.) (statutory Unruh damages can substantially predominate over ADA injunctive relief; supports declining supplemental jurisdiction)