Escobedo v. Estrada

Summary

The United States District Court for the Eastern District of California ordered Plaintiff Jose Escobedo to show cause why the court should not decline supplemental jurisdiction over his California state-law accessibility claims. The order relies on Ninth Circuit precedent concerning federal courts’ discretion under 28 U.S.C. § 1367(c) and California’s restrictions on construction-related accessibility claims by high-frequency litigants.

Holdings

1. Even when supplemental jurisdiction exists under 28 U.S.C. § 1367(a), a district court may exercise its discretion under § 1367(c) to decline supplemental jurisdiction after considering the circumstances of the case, the nature of the state-law claims, the governing state law, and the relationship between the state and federal claims.
2. Because the record indicated that Plaintiff had filed at least ten complaints alleging construction-related accessibility violations within the preceding twelve months, Plaintiff was ordered to show cause within fourteen days why the court should not decline supplemental jurisdiction over his state-law claims.

Questions Presented

1. Whether the court should decline to exercise supplemental jurisdiction over Plaintiff's California state-law claims because Plaintiff is a high-frequency litigant and permitting the claims to proceed in federal court could circumvent California's procedural restrictions.
2. Whether Plaintiff should be required to show cause why the state-law claims should not be dismissed without prejudice under 28 U.S.C. § 1367(c).

Disposition

other