United African-Asian Abilities Club et al. v. Shapell Socal Rental Properties LLC

Summary

The United States District Court for the Central District of California ordered Plaintiffs to show cause why their California Unruh Civil Rights Act claim should not be dismissed without prejudice under 28 U.S.C. § 1367(c)(4). Relying on Ninth Circuit precedent concerning California’s reforms addressing high-frequency litigation, the Court indicated that declining supplemental jurisdiction may protect federal-state comity. Plaintiffs were ordered to identify the statutory damages sought and submit declarations addressing whether they and their counsel qualify as high-frequency litigants.

Holdings

1. Because the Unruh Act claim was closely related to the ADA claim, the court had authority to exercise supplemental jurisdiction over it under 28 U.S.C. § 1367(a).
2. The Ninth Circuit's identified concerns regarding federal-state comity and California's statutory reforms concerning high-frequency ADA-based Unruh Act claims constitute circumstances that may qualify as exceptional under 28 U.S.C. § 1367(c)(4), potentially justifying declination of supplemental jurisdiction.

Questions Presented

1. Whether the court had supplemental jurisdiction over Plaintiffs' Unruh Act claim because it was closely related to the ADA claim.
2. Whether the circumstances identified by the Ninth Circuit in Arroyo v. Rosas potentially warranted declining supplemental jurisdiction over the Unruh Act claim under 28 U.S.C. § 1367(c)(4).
3. Whether, because the case remained at an early stage and the court had not adjudicated the merits, Plaintiffs should be ordered to show cause why the Unruh Act claim should not be dismissed without prejudice.

Disposition

other