Colton Bryant v. Reflections Auto Collision et al.

Summary

The United States District Court for the Central District of California ordered Plaintiff Colton Bryant to show cause why the Court should exercise supplemental jurisdiction over his California state-law disability-access and related claims. The Court discussed 28 U.S.C. § 1367(c), California’s heightened pleading and disclosure requirements for construction-related accessibility claims, and concerns regarding high-frequency litigants. Plaintiff was ordered to identify the statutory damages sought and submit declarations addressing whether Plaintiff and counsel qualify as high-frequency litigants.

Holdings

1. Supplemental jurisdiction is discretionary rather than mandatory, and a federal district court may decline to exercise it under the circumstances specified in 28 U.S.C. § 1367(c), while weighing judicial economy, convenience, fairness, and comity.
2. Before deciding whether to decline supplemental jurisdiction, the court may require plaintiff and counsel to provide declarations and information concerning statutory damages and high-frequency-litigant status under California law.

Questions Presented

1. Whether the court should exercise supplemental jurisdiction over plaintiff's Unruh Act and related state-law claims.
2. What information plaintiff and counsel must provide for the court to determine whether plaintiff or counsel qualifies as a high-frequency litigant under California law.

Disposition

other