Theresa Brooke v. The Cliff House Inn LLC
2:25-cv-03613
| C.D. Cal. | Apr 28, 2025Background
- The plaintiff, Theresa Brooke, filed a complaint in federal court alleging violations of the ADA and seeking damages under California’s Unruh Civil Rights Act related to alleged disability access issues at The Cliff House Inn LLC.
- The plaintiff asks the federal court to exercise supplemental jurisdiction over her Unruh Act claim, which is a state law claim, relying on 28 U.S.C. § 1367.
- The Unruh Act claims in federal court often parallel ADA claims but include statutory damages and are governed by California’s heightened pleading standards to curb abusive disability litigation.
- California law now requires verified complaints and imposes special fees for high-frequency litigants to prevent meritless disability lawsuits.
- The federal court, invoking its discretion under §1367(c), questions whether it should exercise jurisdiction over these state law claims, noting the strong policy interests of California in administering its own disability access litigation.
- The court issues an Order to Show Cause to the plaintiff, requiring justification for why supplemental jurisdiction is appropriate and requesting specific disclosures about damages and plaintiff’s litigant status.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Should the court exercise supplemental jurisdiction over state Unruh Act claims? | Federal court should hear both ADA and Unruh Act claims for efficiency. | State law claims should be handled in state court due to heightened pleading and fee rules. | Court questions jurisdiction; orders plaintiff to justify and provide additional information. |
Key Cases Cited
- City of Chi. v. Int’l Coll. of Surgeons, 522 U.S. 156 (supplemental jurisdiction is discretionary, not a right)
- Carnegie-Mellon Univ. v. Cohill, 484 U.S. 343 (courts must consider factors such as economy, fairness, and comity when exercising supplemental jurisdiction)
- Acri v. Varian Assocs., 114 F.3d 999 (district courts have broad discretion under § 1367(c) to decline jurisdiction over state law claims)
- Schutza v. Cuddeback, 262 F. Supp. 3d 1025 (it is proper to decline jurisdiction over Unruh Act claims to respect California’s interest in curbing abusive litigation)