Theresa Brooke v. 3850 State Street Owner LLC
2:25-cv-05193
| C.D. Cal. | Jun 24, 2025Background
- Plaintiff Theresa Brooke filed a complaint alleging violations of the Americans with Disabilities Act (ADA) and California's Unruh Civil Rights Act (Unruh Act) against 3850 State Street Owner LLC.
- The plaintiff seeks injunctive relief for the alleged ADA violation and damages under the Unruh Act, requesting the court exercise supplemental jurisdiction over the state law claims.
- The court notes it has discretion to exercise or decline supplemental jurisdiction under 28 U.S.C. § 1367(c) if certain conditions are met (novel state law issues, predominance of state law claims, dismissal of federal claims, or other compelling reasons).
- California implemented stricter pleading requirements and additional fees for Unruh Act claims, especially by "high-frequency litigants," to deter frivolous disability litigation.
- The court cites recent district court trends in California, declining supplemental jurisdiction over such Unruh Act claims in favor of letting state courts enforce their own substantial regulatory framework.
- The court issues an order for the plaintiff to show cause why supplemental jurisdiction should be exercised, requiring details about requested statutory damages and whether the plaintiff is a high-frequency litigant.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal court should exercise supplemental jurisdiction over Unruh Act claims | Brooke: Court should exercise jurisdiction for efficiency | 3850 State: State court has greater interest due to specific procedural safeguards | No ruling yet; court orders plaintiff to show cause |
| If plaintiff has satisfied heightened California pleading and filing requirements | Brooke: Complies or will comply | 3850 State: Federal suits may circumvent state requirements | No ruling yet; plaintiff must provide details |
| Whether plaintiff is a "high-frequency litigant" impacting court's discretion | Brooke: Not addressed yet | 3850 State: May argue that heightened scrutiny applies | Court requires disclosure from plaintiff |
| Impact of state interest in regulating disability access litigation on federal jurisdiction | Brooke: Federal and state claims intertwined | 3850 State: State interest outweighs federal claim's predominance | Court emphasizes comity and judicial discretion |
Key Cases Cited
- City of Chicago v. International College of Surgeons, 522 U.S. 156 (discusses discretion in exercising supplemental jurisdiction).
- Carnegie-Mellon Univ. v. Cohill, 484 U.S. 343 (outlines factors for supplemental jurisdiction in federal courts).
- Acri v. Varian Assocs., 114 F.3d 999 (emphasizes district courts' discretion under § 1367(c)).