Guri Gonzalez v. Live DTLA, LLC

Summary

The United States District Court for the Central District of California orders Plaintiff Guri Gonzalez to show cause why his Unruh Act claim should not be dismissed without prejudice under 28 U.S.C. § 1367(c)(4). Relying on Arroyo v. Rosas, the Court identifies exceptional circumstances involving California’s regulation of high-frequency disability-access litigation and directs Plaintiff to provide information concerning his requested statutory damages and high-frequency-litigant status.

Holdings

1. Because Plaintiff's Unruh Act claim is closely related to his ADA claim, the Court has authority to exercise supplemental jurisdiction over the Unruh Act claim under 28 U.S.C. § 1367(a).
2. The circumstances identified in Arroyo v. Rosas, including the effect of retaining federal supplemental jurisdiction on California's statutory reforms addressing high-frequency litigants, may constitute exceptional circumstances under 28 U.S.C. § 1367(c)(4) justifying declination of supplemental jurisdiction.

Questions Presented

1. Whether the Court has supplemental jurisdiction over Plaintiff's Unruh Act claim because it is closely related to his ADA claim.
2. Whether the circumstances identified by the Ninth Circuit in Arroyo v. Rosas constitute exceptional circumstances under 28 U.S.C. § 1367(c)(4) that may justify declining supplemental jurisdiction over an ADA-based Unruh Act claim.
3. Whether Plaintiff should be required to show cause why the Unruh Act claim should not be dismissed without prejudice.

Disposition

other