Theresa Brooke v. Inn on the Beach LLC
2:25-cv-04598
C.D. Cal.May 22, 2025Background
- Theresa Brooke, a wheelchair user, sued Inn on the Beach LLC, alleging inadequate parking in violation of the Americans with Disabilities Act (ADA) and California's Unruh Act.
- The ADA claim provides original federal jurisdiction, while the Unruh Act claim could be heard under supplemental jurisdiction.
- The Unruh Act allows statutory damages, and California amended it to deter abuse by high-frequency plaintiffs, leading to a shift of such cases to federal court.
- The Ninth Circuit in Arroyo v. Rosas recognized that exercising supplemental jurisdiction over these state claims in federal court could undermine California’s reforms.
- The district court is considering declining supplemental jurisdiction over the Unruh Act claim early in the case, prior to reaching the merits.
- Plaintiff is ordered to show cause within 14 days why her Unruh Act claim should not be dismissed without prejudice; if she does not, the claim will be automatically dismissed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Should the court exercise supplemental jurisdiction over the Unruh Act claim? | Unruh Act claim is related to ADA claim and should be heard together | Federal courts should decline such claims to vindicate state reforms | Court is inclined to decline jurisdiction under § 1367(c)(4) |
| Does the case present exceptional circumstances justifying declination of jurisdiction? | No exceptional circumstances | Arroyo justifies declination | Exceptional circumstances exist per Arroyo |
Key Cases Cited
- City of Chi. v. Int'l Coll. of Surgeons, 522 U.S. 156 (district courts have discretion to decline supplemental jurisdiction)
- Arroyo v. Rosas, 19 F.4th 1202 (9th Cir. 2021) (retention of supplemental jurisdiction over Unruh Act claims threatens California’s state-law policy objectives)