Robert Cauley v. Sharlize Jon LLC

Summary

The United States District Court for the Central District of California issued an order to show cause regarding Plaintiff Robert Cauley’s Unruh Act claim accompanying his ADA claim. Citing 28 U.S.C. § 1367(c)(4) and Arroyo v. Rosas, the Court directed Plaintiff to explain why the Court should not decline supplemental jurisdiction and dismiss the Unruh Act claim without prejudice, including by identifying the requested statutory damages and providing facts concerning high-frequency-litigant status.

Holdings

1. A district court may decline supplemental jurisdiction over an ADA-based Unruh Act claim under § 1367(c)(4) when the circumstances create exceptional concerns regarding California's statutory reforms, federal-state comity, and the role of California courts in enforcing those reforms.
2. The court should require Plaintiff to show cause, within 14 days, why the Unruh Act claim should not be dismissed without prejudice for lack of supplemental jurisdiction, including by identifying the damages sought and providing facts relevant to whether Plaintiff and counsel are high-frequency litigants.

Questions Presented

1. Whether the district court may decline supplemental jurisdiction over Plaintiff's ADA-based Unruh Act claim under 28 U.S.C. § 1367(c)(4) based on the federal-state comity concerns identified in Arroyo v. Rosas.
2. Whether Plaintiff should be required to show cause why the Unruh Act claim should not be dismissed without prejudice at this early stage of the litigation.

Disposition

other