Theresa Brooke v. Crystal Lodge LLC
2:25-cv-03314
| C.D. Cal. | Apr 18, 2025Background
- Plaintiff Theresa Brooke filed suit against Crystal Lodge LLC, alleging violations of the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act in the Central District of California.
- The ADA claim is based on federal law, while the Unruh Act claim seeks statutory damages under state law.
- The court questions whether it should exercise supplemental jurisdiction over the state law Unruh Act claim and any additional state law claims asserted.
- California has specific statutes aimed at regulating high-frequency litigants in disability access cases, including heightened pleading standards and filing fees.
- The federal district courts, supported by Ninth Circuit precedent, have often declined supplemental jurisdiction in such disability access cases, citing unique state interests and legislative intent.
- The court ordered Brooke to show cause why it should retain jurisdiction over the Unruh Act claim, requiring detailed declarations and identification of damages sought, with a deadline to respond or risk dismissal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court should exercise supplemental jurisdiction over state Unruh Act claims in an ADA lawsuit | Federal court has authority to consider both ADA and related state claims for efficiency and judicial economy | State Unruh Act claims raise unique policy concerns; California wants to regulate high-frequency filings; federal courts should defer to state forum | Court requires plaintiff to show cause; may decline jurisdiction if concerns not addressed |
Key Cases Cited
- City of Chicago v. Int’l Coll. of Surgeons, 522 U.S. 156 (decides that courts should consider judicial economy, fairness, and comity when deciding supplemental jurisdiction)
- Carnegie-Mellon Univ. v. Cohill, 484 U.S. 343 (establishes factors for declining supplemental jurisdiction)
- Vo v. Choi, 49 F.4th 1167 (9th Cir. 2022) (upholds dismissal of state law disability access claims by federal courts under exceptional circumstances)
- Arroyo v. Rosas, 19 F.4th 1202 (9th Cir. 2021) (court may decline supplemental jurisdiction when state interest in regulating high-frequency claims is strong)