Summary
The United States District Court for the Central District of California ordered Plaintiff Julio Cruz to show cause why the Court should exercise supplemental jurisdiction over his state law claims under 28 U.S.C. § 1367. The order identifies potential exceptional circumstances in ADA and Unruh Act litigation and directs Plaintiff to disclose the statutory damages sought and provide declarations addressing whether Plaintiff and counsel qualify as high-frequency litigants under California law. A response was ordered by October 9, 2025.
Topics
Practice areas
Questions Presented
- Whether the court should exercise supplemental jurisdiction over plaintiff's state-law claims arising from the same action as his ADA claim.
- Whether plaintiff must provide information concerning the statutory damages sought and whether he satisfies California's definition of a high-frequency litigant before the court decides whether to exercise supplemental jurisdiction.
Holdings
- Supplemental jurisdiction is discretionary rather than a right of the plaintiff, and a district court may decline to exercise it under the circumstances identified in 28 U.S.C. § 1367(c).
- The plaintiff was required to show cause why the court should exercise supplemental jurisdiction over the state-law claims and to provide information relevant to the statutory damages sought and his status as a potential high-frequency litigant.
Key quotations
“Supplemental jurisdiction “is a doctrine of discretion, not of plaintiff’s right.”” (at 1)
“Failure to respond to this Order may result in the Court declining to exercise supplemental jurisdiction over Plaintiff’s state law claims.” (at 2)
Factual background
Julio Cruz alleged that Euclid Best Bargain and unnamed Doe defendants violated the ADA, the Unruh Civil Rights Act, and other state laws. He sought ADA injunctive relief and statutory damages under the Unruh Act and California Disabled Persons Act. The court noted that ADA/Unruh litigation may implicate California procedural requirements designed to limit certain litigation and therefore may present exceptional circumstances warranting declination of supplemental jurisdiction.
Procedural history
Plaintiff filed an action asserting claims under the Americans with Disabilities Act, California's Unruh Civil Rights Act, and other state laws. He alleged federal-question jurisdiction over the ADA claim and supplemental jurisdiction over the state-law claims. The court ordered plaintiff to respond regarding supplemental jurisdiction and warned that failure to respond could result in the court declining jurisdiction over the state-law claims.