Yuri Doering v. Samuel Vasquez, 2:23-cv-09351

Plaintiff, Yuri Doering, who has a physical disability and uses a wheelchair, visited Samanta’s Meat Market in Huntington Park, CA in August 2023 and encountered alleged accessibility barriers, particularly with parking.
Doering filed a complaint in federal court under the Americans with Disabilities Act (ADA) for injunctive relief and several California state law claims (Unruh Act, California Disabled Persons Act, Health and Safety Code, and negligence) seeking monetary and injunctive relief.
ADA claims in federal court allow only for injunctive relief, while the state law claims, particularly the Unruh Act, enable monetary damages and have additional procedural requirements for “high-frequency litigants.”
Doering was ordered by the court to show why supplemental jurisdiction over his state claims was appropriate, considering California’s heightened standards for high-frequency ADA litigants.
The court found that Doering qualifies as a high-frequency litigant and that his state claims, which predominate in terms of remedy sought, are subject to state-specific procedural mechanisms intended to limit perceived abuse.
The court declined supplemental jurisdiction over the state claims at this early stage, dismissing them without prejudice to allow state courts to enforce California’s unique pleading and fee requirements.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Should the court exercise supplemental jurisdiction over state law accessibility claims?	Doering argued there’s no meaningful difference between state and federal process, and his claims should be heard together.	Not detailed (Defendant had not yet appeared), but court analyzed based on comity/fairness to defendants.	Court declined to exercise supplemental jurisdiction over state law claims due to predominance and comity concerns.
Whether Doering qualifies as a "high-frequency litigant" under California law, triggering heightened requirements.	Doering admitted to qualifying as a high-frequency litigant.	Not detailed.	Court found Doering qualifies and the requirements should be enforced by state courts.
Do the state law claims predominate over the federal ADA claim?	Doering sought damages and injunction under state law and only injunction under ADA.	Not detailed.	Court held the monetary damages and remedies under state law predominate over federal injunctive relief.
Are there “exceptional circumstances” justifying the court’s refusal of supplemental jurisdiction?	Doering argued federal court should retain jurisdiction.	Not detailed.	Court ruled the unique California procedures, legislative intent, and Ninth Circuit precedent present “exceptional circumstances.”

Chicago v. Int’l Coll. of Surgeons, 522 U.S. 156 (federal courts should weigh economy, convenience, fairness, and comity when deciding supplemental jurisdiction)
Carnegie-Mellon Univ. v. Cohill, 484 U.S. 343 (sets standards for pendent and supplemental jurisdiction discretion)
Wander v. Kaus, 304 F.3d 856 (only injunctive relief is available under ADA)
Molski v. M.J. Cable, Inc., 481 F.3d 724 (Unruh Act statutory damages available without proof of actual injury)
United Mine Workers of Am. v. Gibbs, 383 U.S. 715 (state law claims that predominate justify dismissal from federal court)