Michael Rhambo v. The Cigar Empire Inc., et al.

Summary

The United States District Court for the Central District of California ordered Plaintiff Michael Rhambo to show cause why the Court should exercise supplemental jurisdiction over claims under California's Unruh Civil Rights Act and other state laws. The Court required a response addressing the amount of statutory damages sought and facts relevant to whether Plaintiff or counsel qualifies as a high-frequency litigant under California law, with a filing deadline of May 15, 2025.

Holdings

1. A federal court may raise the question of subject-matter jurisdiction sua sponte at any time during the pendency of the action, and the court has an obligation to confirm that jurisdiction exists.
2. The court may decline to exercise supplemental jurisdiction over ADA-based Unruh Civil Rights Act claims under 28 U.S.C. § 1367(c), including where the claim presents a substantial federal-state-comity concern.

Questions Presented

1. Whether the court should exercise supplemental jurisdiction over the Unruh Civil Rights Act claim and the other state-law claims.
2. Whether the court has a sua sponte duty to confirm its subject-matter jurisdiction.
3. Whether Plaintiff must provide information concerning requested Unruh Act statutory damages and high-frequency-litigant status before the court determines whether to exercise supplemental jurisdiction.

Disposition

other