Sepulveda v. Guo

Summary

The United States District Court for the Northern District of California granted defendants’ motion to dismiss Richard Sepulveda’s Unruh Civil Rights Act and related state-law claims. Applying 28 U.S.C. § 1367(c)(4) and Ninth Circuit precedent, the court held that California’s reforms concerning high-frequency litigants constituted an exceptional circumstance supporting the decline of supplemental jurisdiction. The claims were dismissed without prejudice to refiling in state court, while the court set a case management conference for April 4, 2023.

Holdings

1. California's reforms governing high-frequency Unruh Act litigants, and the evasion of those reforms through filing ADA-based Unruh Act claims in federal court, constituted an exceptional circumstance under 28 U.S.C. § 1367(c)(4) supporting declination of supplemental jurisdiction.
2. The values of economy, convenience, fairness, and comity favored declining supplemental jurisdiction because the case was still in its early stages and the federal court had not fully adjudicated the federal and state claims.

Questions Presented

1. Whether California's procedural and damages reforms governing high-frequency Unruh Act litigants constituted an exceptional circumstance under 28 U.S.C. § 1367(c)(4) permitting the court to decline supplemental jurisdiction over ADA-based Unruh Act and related state-law claims.
2. Whether the Gibbs values of economy, convenience, fairness, and comity supported declining supplemental jurisdiction because the case remained in its early stages.

Disposition

dismissed