James Alger v. Ashford CM Partners LP et al.

Summary

The United States District Court for the Central District of California denied Ashford CM Partners LP and Ashford TRS CM LLC’s motion to dismiss James Alger’s ADA claim. The court held that a California small claims judgment did not preclude the ADA claim because the small claims court lacked jurisdiction to award the injunctive relief available under the ADA, and the Rooker-Feldman doctrine did not apply because the state-court judgment was entered after the federal action began. The court also ordered Ashford’s counsel to show cause why sanctions should not be imposed under Federal Rule of Civil Procedure 11(b)(2) for allegedly misrepresenting authority.

Holdings

1. Issue preclusion did not apply because California courts generally do not apply issue preclusion to small claims actions, and in any event the conclusory small claims judgment did not adequately reflect the issues actually litigated and decided.
2. The small claims judgment did not preclude Alger's ADA claim because the small claims court was not a court of competent jurisdiction to adjudicate the ADA claim and grant the only relief available to a private ADA plaintiff: injunctive relief.
3. The Rooker-Feldman doctrine did not apply because the state small claims judgment was entered after the federal action commenced.
4. Defense counsel was ordered to show cause why sanctions should not be imposed for allegedly misrepresenting Guerrero's holding by presenting language from Mattson v. City of Costa Mesa as though it were Guerrero's holding.

Questions Presented

1. Whether the California small claims judgment precluded Alger's federal ADA claim under claim or issue preclusion.
2. Whether the California small claims court was a court of competent jurisdiction for purposes of precluding an ADA claim seeking injunctive relief.
3. Whether the Rooker-Feldman doctrine barred the federal action because of the state small claims judgment.
4. Whether defense counsel should be ordered to show cause under Federal Rule of Civil Procedure 11(b)(2) for allegedly misrepresenting the holding of Guerrero v. Department of Corrections and Rehabilitation.

Disposition

other