Acevedo v. Akari

District Court, E.D. California·Decided October 23, 2024·No. 1:24-cv-01199·Unknown

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 CESAR ACEVEDO, Case No. 1:24-cv-01199-CDB 12 Plaintiff, FINDINGS AND RECOMMENDATIONS TO DECLINE SUPPLEMENTAL JURISDICTION 13 v. OVER PLAINTIFF’S STATE LAW CLAIMS 14 RASEM A. AKARI, et al., (Docs. 1, 6) 15 Defendants. 14-DAY DEADLINE 16 Clerk of the Court to Assign District Judge 17 18 Background 19 On October 4, 2024, Plaintiff Cesar Acevedo filed this case against Defendants Rasem A. 20 Akari, doing business as Mountain View Mart, and Manhal Khalil (“Defendants”). (Doc. 1). 21 Plaintiff’s complaint asserts claims for injunctive relief under the Americans with Disabilities Act 22 of 1990 (“ADA”), violation of California’s Unruh Civil Rights Act (“Unruh Act”), violation of 23 California Disabled Persons Act, and related state law causes of action. Id. These claims stem 24 from alleged barriers Plaintiff encountered while visiting a facility owned, operated, or leased by 25 Defendants. Id. at 3. No Defendant has appeared. 26 On October 8, 2024, the undersigned ordered Plaintiff to show cause why the Court 27 should not decline to exercise supplemental jurisdiction over his Unruh Act claim in light of the 28 1 Ninth Circuit’s decision in Vo v. Choi. (Doc. 5). Vo v. Choi, 49 F.4th 1167 (9th Cir. 2022) 2 (affirming a district court’s decision to decline supplemental jurisdiction over an Unruh Act 3 claim); see 28 U.S.C. § 1367(c). Plaintiff timely filed a response to the Court’s show cause order 4 on October 22, 2024. (Doc. 6). For the reasons given below, the undersigned will recommend that 5 the Court decline to exercise supplemental jurisdiction over Plaintiff’s state law claims and 6 dismiss these claims without prejudice to Plaintiff’s refiling in state court. 7 Governing Legal Standards 8 Under 28 U.S.C. § 1367(a), a court that has original jurisdiction over a civil action “shall 9 have supplemental jurisdiction over all other claims that are so related to claims in the action 10 within such original jurisdiction that they form part of the same case or controversy under Article 11 III of the United States Constitution.” The Ninth Circuit has concluded that ADA and Unruh Act 12 claims that derive from a common nucleus of operative fact “form part of the ‘same case or 13 controversy’ for purposes of § 1367(a).” Arroyo v. Rosas, 19 F.4th 1202, 1209 (9th Cir. 2021). 14 However, even where supplemental jurisdiction over a claim exists under § 1367(a), the 15 Court may decline jurisdiction over the claim if: 16 (1) the claim raises a novel or complex issue of State law, 17 (2) the claim substantially predominates over the claim or claims over which the 18 district court has original jurisdiction, 19 (3) the district court has dismissed all claims over which it has original 20 jurisdiction, or 21 (4) in exceptional circumstances, there are other compelling reasons for declining 22 jurisdiction. 23 § 1367(c)(1)-(4). 24 Pertinent here, a court deciding whether to apply § 1367(c)(4) must undertake “a two-part 25 inquiry.” Arroyo, 19 F.4th at 1210. “First, the district court must articulate why the circumstances 26 of the case are exceptional within the meaning of § 1367(c)(4).” Id. (citations and internal 27 quotation marks omitted). “Second, in determining whether there are compelling reasons for 28 declining jurisdiction in a given case, the court should consider what best serves the principles of 1 economy, convenience, fairness, and comity which underlie the pendent jurisdiction doctrine 2 articulated in [United Mine Workers of Am. v. Gibbs, 383 U.S. 715 (1966)].” Id. (citations and 3 internal quotation omitted). 4 After considering § 1367(c)(4) and California’s requirements for bringing Unruh Act 5 claims, “numerous district courts in California ‘have declined to exercise supplemental 6 jurisdiction over Unruh Act . . . claims brought alongside ADA claims.’” Block v. Cal.-Fresno 7 Invest. Co., No. 1:22-cv-1419 JLT SAB, 2023 WL 8675398, at *4 (E.D. Cal. Dec. 15, 2023) 8 (quoting Rutherford v. Nuway Ins. Agency Inc., No. SACV 21-00576-CJC-JDE, 2021 WL 9 4572008, at *1 (C.D. Cal. Apr. 1, 2021)). Underlying these decisions is “the recent confluence of 10 several California-law rules [that] have combined to create a highly unusual systemic impact on 11 ADA-based Unruh Act cases that clearly threatens to have a significant adverse impact on 12 federal-state comity.” Arroyo, 19 F.4th at 1211. 13 Notably, Congress adopted the ADA to address the discrimination encountered by persons 14 with disabilities, providing a private cause of action to seek injunctive, but not monetary, relief. 15 See id. at 1205 (discussing background and relief available under the ADA). And the Unruh Act 16 likewise prohibits disability discrimination, containing a provision, Cal. Civ. Code § 51(f), stating 17 that a violation of the ADA also violates the Unruh Act. However, unlike the ADA, the Unruh 18 Act allows a plaintiff to recover “up to a maximum of three times the amount of actual damage 19 but in no case less than four thousand dollars.” Cal. Civ. Code § 52(a). 20 In response to perceived abuses of the Unruh Act, California has enacted requirements for 21 bringing such claims, which requirements the Ninth Circuit has assumed, without deciding, 22 “apply only in California state court.” Vo, 49 F.4th at 1170. For example, provisions were added 23 (1) regarding the contents of demand letters, Cal. Civ. Code § 55.31; (2) imposing heightened 24 pleading requirements, Cal. Civ. Code § 425.50(a); and (3) requiring an additional filing fee of 25 $1,000 for so called “high-frequency litigants,” Cal. Gov’t Code § 70616.5(b), see Cal. Civ. Code 26 § 425.55(b) (defining a high-frequency litigant to include “[a] plaintiff who has filed 10 or more 27 complaints alleging a construction-related accessibility violation within the 12-month period 28 immediately preceding the filing of the current complaint alleging a construction-related 1 accessibility violation”). 2 All of these requirements1 apply to claims alleging a construction-related accessibility 3 violation, defined as involving “a provision, standard, or regulation under state or federal law 4 requiring compliance with standards for making new construction and existing facilities 5 accessible to persons with disabilities,” including those related to the ADA. Cal. Civ. Code 6 § 55.52(a)(1), (6); see Cal. Civ. Code § 55.3(a)(2). By enacting such restrictions, California has 7 expressed a “desire to limit the financial burdens California’s businesses may face from claims 8 for statutory damages under the Unruh Act.” Arroyo, 19 F.4th at 1209 (internal quotations 9 omitted). However, “Unruh Act plaintiffs have evaded these limits by filing in a federal forum in 10 which [they] can claim these state law damages in a manner inconsistent with the state law’s 11 requirements.” Id. at 1213 (internal quotation omitted).

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