Theresa Brooke v. Ennerdale Oxnard LLC, 2:25-cv-03316

Plaintiff Theresa Brooke filed a lawsuit against Ennerdale Oxnard LLC, alleging violations of both the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act (Unruh Act).
The ADA claim seeks declaratory and injunctive relief, as well as costs and attorney’s fees.
The Unruh Act claim seeks $4,000 in damages, declaratory judgment, injunctive relief, and attorney’s fees.
California law imposes heightened pleading standards and specific requirements for lawsuits brought under the Unruh Act by so-called “high-frequency litigants.”
The Court, considering its discretion under 28 U.S.C. § 1367, issued an Order to Show Cause as to why it should exercise supplemental jurisdiction over the state law (Unruh Act) claim, given potential concerns about comity and statutory requirements.
Plaintiff was ordered to respond with declarations confirming whether she and/or her counsel meet the definition of “high-frequency litigant” under California law.

Issue	Plaintiff’s Argument	Defendant’s Argument	Held
Whether the Court should retain	Federal court has subject	State law claims are subject	Court ordered Plaintiff to show cause; did not yet decide to
supplemental jurisdiction over	matter jurisdiction over ADA claim	to stricter standards and	exercise or decline supplemental jurisdiction over the Unruh Act.
Unruh Act claim	and can exercise supplemental	may overwhelm federal dockets;
	jurisdiction over related state law	comity and fairness concerns.
	claims under 28 U.S.C. § 1367.

City of Chicago v. Int’l Coll. of Surgeons, 522 U.S. 156 (1997) (federal courts must consider judicial economy, convenience, fairness, and comity when deciding on supplemental jurisdiction)
Carnegie-Mellon Univ. v. Cohill, 484 U.S. 343 (1988) (articulates factors for declining supplemental jurisdiction)