Colton Bryant v. Dilip Solanki

Summary

The United States District Court for the Central District of California issued an order to show cause concerning Plaintiff’s Unruh Act claim accompanying his ADA accessibility claims. Relying on Ninth Circuit precedent regarding California’s high-frequency litigant reforms and federal-state comity, the Court ordered Plaintiff to explain why the Unruh Act claim should not be dismissed without prejudice for lack of supplemental jurisdiction.

Holdings

1. Because the Unruh Act claim is closely related to the ADA claim, the court has authority under 28 U.S.C. § 1367(a) to exercise supplemental jurisdiction over it.
2. The circumstances identified by the Ninth Circuit in Arroyo v. Rosas—particularly the effect of federal ADA litigation seeking Unruh Act statutory damages on California's statutory reforms and state-court role—qualify as exceptional circumstances that may justify declining supplemental jurisdiction under 28 U.S.C. § 1367(c)(4).

Questions Presented

1. Whether the district court may exercise supplemental jurisdiction over Plaintiff's closely related Unruh Act claim under 28 U.S.C. § 1367(a).
2. Whether exceptional circumstances under 28 U.S.C. § 1367(c)(4), including the federalism and comity concerns identified in Arroyo v. Rosas, warrant declining supplemental jurisdiction over the Unruh Act claim at this early stage.
3. What information Plaintiff must provide to show cause why the Unruh Act claim should not be dismissed without prejudice.

Disposition

other