Melanie Delapaz v. Mitsuko Osuga et al.

Summary

The United States District Court for the Central District of California issued an order to show cause concerning Plaintiff Melanie Delapaz’s Unruh Act claim arising from alleged ADA-accessibility barriers. The Court indicated that it may decline supplemental jurisdiction under 28 U.S.C. § 1367(c)(4) based on the federalism and comity concerns identified in Arroyo v. Rosas, and ordered Plaintiff to explain why the claim should not be dismissed without prejudice.

Holdings

1. Because the Unruh Act claim was closely related to the ADA claim, the court had authority to exercise supplemental jurisdiction under 28 U.S.C. § 1367(a), but supplemental jurisdiction remained discretionary rather than a right of the plaintiff.
2. At the preliminary order-to-show-cause stage, the circumstances identified in Arroyo v. Rosas appeared to support declining supplemental jurisdiction over the ADA-based Unruh Act claim under § 1367(c)(4), subject to plaintiff's response.

Questions Presented

1. Whether the court had supplemental jurisdiction over plaintiff's closely related Unruh Act claim.
2. Whether exceptional circumstances under 28 U.S.C. § 1367(c)(4), including the federalism and comity concerns identified in Arroyo v. Rosas, warranted declining supplemental jurisdiction over the Unruh Act claim before adjudication of the merits.

Disposition

other