Yuri Doering v. JB Auto Repair Inc.

Summary

The United States District Court for the Central District of California orders Plaintiff Yuri Doering to show cause why his California Unruh Act claim should not be dismissed without prejudice under 28 U.S.C. § 1367(c)(4). The order relies on Ninth Circuit precedent recognizing exceptional federalism and comity concerns when federal courts exercise supplemental jurisdiction over ADA-based Unruh Act claims, and requires Plaintiff to provide information concerning damages and high-frequency-litigant status.

Holdings

1. Because Plaintiff's Unruh Act claim is closely related to his ADA claim, the Court has authority under 28 U.S.C. § 1367(a) to exercise supplemental jurisdiction over the Unruh Act claim.
2. The Court preliminarily determined that the circumstances identified by the Ninth Circuit in Arroyo v. Rosas appear to provide a basis for declining supplemental jurisdiction over Plaintiff's Unruh Act claim under 28 U.S.C. § 1367(c)(4), but deferred a final decision and required Plaintiff to show cause.
3. Plaintiff was required to respond within 14 days after entry of the order, identify the statutory damages sought, and submit sworn declarations containing facts necessary to determine whether Plaintiff and his counsel satisfy the California definition of a high-frequency litigant; failure to respond would result in dismissal without prejudice of the Unruh Act claim without further order.

Questions Presented

1. Whether the Court may exercise supplemental jurisdiction over Plaintiff's closely related Unruh Act claim under 28 U.S.C. § 1367(a).
2. Whether the circumstances identified in Arroyo v. Rosas may constitute exceptional circumstances and compelling reasons under 28 U.S.C. § 1367(c)(4) to decline supplemental jurisdiction over an ADA-based Unruh Act claim at an early stage of the case.
3. What information Plaintiff must provide to show cause why the Unruh Act claim should not be dismissed without prejudice.

Disposition

other