Korttney Elliott v. Joeun Enterprises, Inc.

Summary

The United States District Court for the Central District of California ordered Plaintiff to show cause why her California Unruh Civil Rights Act claim should not be dismissed without prejudice for lack of supplemental jurisdiction. The order relies on 28 U.S.C. § 1367(c)(4) and Arroyo v. Rosas to identify exceptional circumstances involving California’s regulation of high-frequency disability-access litigation and related federal-state comity concerns. Plaintiff was directed to identify the statutory damages sought and provide declarations addressing whether she and her counsel qualify as high-frequency litigants.

Holdings

1. A district court may decline to exercise supplemental jurisdiction over an ADA-based Unruh Act claim when exceptional circumstances and compelling federal-state comity concerns exist under 28 U.S.C. § 1367(c)(4), particularly where retaining the claim could circumvent California's statutory reforms concerning high-frequency litigants.

Questions Presented

1. Whether the court should decline supplemental jurisdiction over Plaintiff's Unruh Act claim under 28 U.S.C. § 1367(c)(4) based on the exceptional circumstances and federal-state comity concerns identified in Arroyo v. Rosas.
2. Whether Plaintiff should be required to show cause why the Unruh Act claim should not be dismissed without prejudice before the court made a final jurisdictional determination.

Disposition

other