Theresa Brooke v. El Patio Beachside Inn Inc., 2:25-cv-05194

Plaintiff Theresa Brooke sued El Patio Beachside Inn Inc., alleging disability discrimination under Title III of the Americans with Disabilities Act (ADA) and California's Unruh Civil Rights Act (Unruh Act).
The complaint seeks injunctive relief under the ADA and statutory damages under the Unruh Act, requesting the federal court exercise supplemental jurisdiction over the state law claim.
Federal courts have discretion to decline supplemental jurisdiction over state law claims, per 28 U.S.C. § 1367(c).
California has implemented heightened pleading standards and additional fees for high-frequency litigants to curb abusive disability access litigation under the Unruh Act.
Other district courts in California often decline to hear Unruh Act claims in federal ADA cases, favoring California's interest in regulating such actions in its own courts.
The court issued this Order to Show Cause, requiring Plaintiff to explain why supplemental jurisdiction should be exercised and to disclose relevant information, including damages sought and high-frequency litigant status.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Should the federal court exercise supplemental jurisdiction over the Unruh Act claim?	Brooke requests the court retain jurisdiction for efficiency and complete relief.	El Patio may argue state law claims should be addressed in state court given California's interest and standards.	The court did not rule, but ordered Plaintiff to show cause why jurisdiction should be retained, citing judicial discretion.

City of Chicago v. Int’l College of Surgeons, 522 U.S. 156 (federal courts have discretion to decline supplemental jurisdiction over state law claims)
Acri v. Varian Assocs., 114 F.3d 999 (9th Cir. 1997) (district courts possess discretion under § 1367(c) to decline supplemental jurisdiction)
Carnegie-Mellon Univ. v. Cohill, 484 U.S. 343 (factors such as judicial economy, fairness, and comity guide supplemental jurisdiction decisions)