Jardine Gougis v. David Morales

Summary

The United States District Court for the Central District of California issued an order requiring the plaintiff to show cause why the court should not decline supplemental jurisdiction over state-law claims under 28 U.S.C. § 1367. The court identified the plaintiff's alleged status as a high-frequency litigant and the state's heightened requirements for construction-related accessibility claims as relevant to the jurisdictional analysis. The plaintiff was ordered to respond by July 14, 2025, including identifying the statutory damages sought and submitting a supporting declaration.

Holdings

1. A district court may exercise supplemental jurisdiction over state-law claims that form part of the same Article III case or controversy as claims within the court's original jurisdiction, but supplemental jurisdiction is discretionary rather than a right of the plaintiff.
2. The court required Plaintiff to show cause why it should not decline supplemental jurisdiction over the state-law claims, based on the possibility that exercising federal jurisdiction would permit a high-frequency plaintiff to circumvent California's heightened pleading and related statutory requirements.

Questions Presented

1. Whether the court should exercise supplemental jurisdiction over Plaintiff's California state-law accessibility claims under 28 U.S.C. § 1367.
2. Whether Plaintiff should be required to show cause why the state-law claims should not be dismissed without prejudice because exercising federal supplemental jurisdiction could allow a high-frequency litigant to avoid California's special statutory requirements.

Disposition

other