Leemanuel Weilch v. Dokument USA, Inc. et al.

Summary

The Central District of California orders Plaintiff Leemanuel Weilch to show cause why his California Unruh Act claim should not be dismissed without prejudice for lack of supplemental jurisdiction. Relying on Ninth Circuit precedent concerning California’s regulation of high-frequency disability litigation, the Court states that exceptional circumstances may warrant declining jurisdiction under 28 U.S.C. § 1367(c)(4) and requires Plaintiff to provide information concerning damages and high-frequency-litigant status.

Holdings

1. The Unruh Act claim is within the court's supplemental jurisdiction because it is closely related to the ADA claim, but supplemental jurisdiction is discretionary rather than a right of the plaintiff.
2. The circumstances identified by the Ninth Circuit in Arroyo v. Rosas can constitute exceptional circumstances under § 1367(c)(4) supporting a district court's decision to decline supplemental jurisdiction over an ADA-based Unruh Act claim, particularly where the case remains at an early stage and the state-law claim has not been adjudicated.

Questions Presented

1. Whether the Unruh Act claim falls within the district court's supplemental jurisdiction because it is closely related to the ADA claim.
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 of the litigation.

Disposition

other