Gastelum v. Tilly's, Inc.

CourtDistrict Court, E.D. California
DecidedFebruary 3, 2025
Docket1:22-cv-00178
StatusUnknown

This text of Gastelum v. Tilly's, Inc. (Gastelum v. Tilly's, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gastelum v. Tilly's, Inc., (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 FERNANDO GASTELUM, Case No. 1:22-cv-00178-KES-CDB 12 Plaintiff, ORDER VACATING OCTOBER 30, 2024, FINDINGS AND RECOMMENDATIONS 13 v. (Doc. 36) 14 TILLY’S, INC., FINDINGS AND RECOMMENDATIONS TO 15 Defendant. (1) GRANT DEFENDANT’S MOTION TO DISMISS AND DECLINE SUPPLEMENTAL 16 JURISDICTION OVER PLAINTIFF’S STATE LAW CLAIM, (2) DENY PLAINTIFF’S 17 MOTION FOR LEAVE TO AMEND, and (3) DISMISS PLAINTIFF’S UNRUH ACT CLAIM 18 WITHOUT PREJUDICE

19 (Docs. 6, 38)

20 14-DAY OBJECTION PERIOD 21 22 On February 11, 2022, Plaintiff Fernando Gastelum (“Plaintiff”) initiated this action with 23 the filing of a complaint against Defendant Tilly’s, Inc.1 (“Defendant”) alleging violations of the 24 American with Disabilities Act (ADA) and California’s Unruh Civil Rights Act. (Doc. 1). These 25 claims stem from alleged barriers Plaintiff encountered while visiting two facilities owned by 26 Defendant. (Id. ¶¶ 3, 8-13). 27 1 Defendant World of Jeans & Tops dba Tillys (“Defendant”) notes it is erroneously sued 28 as Tilly’s, Inc. (Doc. 6 at 1). 1 I. Order Vacating October 30, 2024, Findings and Recommendations 2 On March 25, 2022, Defendant filed its motion to dismiss for lack of supplemental 3 jurisdiction a claim asserted by Plaintiff pursuant to California’s Unruh Civil Rights Act (the second 4 cause of action in Plaintiff’s operative complaint). (Doc. 6). Plaintiff timely filed an opposition 5 on March 30, 2022, and Defendant replied on April 26, 2022. (Docs. 9, 11). Plaintiff thereafter 6 filed two notices of supplemental authority; Defendant filed a response to the first. (Docs. 12-14). 7 On August 1, 2024, the assigned district judge referred Defendant’s motion to the undersigned for 8 preparations of findings and recommendations. (Doc. 34). 9 On October 30, 2024, the undersigned issued findings and recommendations to decline 10 supplemental jurisdiction over Plaintiff’s state law claim, and grant Defendant’s motion to dismiss 11 that claim without prejudice to Plaintiff’s filing of the claim in state court. (Doc. 36). Plaintiff was 12 afforded 14 days after service of the order to file any objections. (Id. at 9). No objections were 13 filed, however, on November 15, 2024, Plaintiff lodged the first amended complaint (“FAC”) and 14 filed the pending motion for leave to amend. (Docs. 37, 38). 15 II. Defendant’s Motion to Dismiss Plaintiff’s Unruh Act Claim (Doc. 6) 16 A. Governing Legal Standards 17 Under 28 U.S.C. § 1367(a), a court that has original jurisdiction over a civil action “shall 18 have supplemental jurisdiction over all other claims that are so related to claims in the action within 19 such original jurisdiction that they form part of the same case or controversy under Article III of 20 the United States Constitution.” The Ninth Circuit has concluded that ADA and Unruh Act claims 21 that derive from a common nucleus of operative fact “form part of the ‘same case or controversy’ 22 for purposes of § 1367(a).” Arroyo v. Rosas, 19 F.4th 1202, 1209 (9th Cir. 2021). 23 However, even where supplemental jurisdiction over a claim exists under § 1367(a), the 24 Court may decline jurisdiction over the claim if: 25 (1) the claim raises a novel or complex issue of State law, 26 (2) the claim substantially predominates over the claim or claims over which the 27 district court has original jurisdiction, 28 (3) the district court has dismissed all claims over which it has original jurisdiction, 1 or 2 (4) in exceptional circumstances, there are other compelling reasons for declining 3 jurisdiction. 4 § 1367(c)(1)-(4). 5 Pertinent here, a court deciding whether to apply § 1367(c)(4) must undertake “a two-part 6 inquiry.” Arroyo, 19 F.4th at 1210. “First, the district court must articulate why the circumstances 7 of the case are exceptional within the meaning of § 1367(c)(4).” (Id.) (citations and internal 8 quotation marks omitted). “Second, in determining whether there are compelling reasons for 9 declining jurisdiction in a given case, the court should consider what best serves the principles of 10 economy, convenience, fairness, and comity which underlie the pendent jurisdiction doctrine 11 articulated in [United Mine Workers of Am. v. Gibbs, 383 U.S. 715 (1966)].” (Id.) (citations and 12 internal quotation omitted). 13 After considering § 1367(c)(4) and California’s requirements for bringing Unruh Act 14 claims, “numerous district courts in California ‘have declined to exercise supplemental jurisdiction 15 over Unruh Act . . . claims brought alongside ADA claims.’” Block v. Cal.-Fresno Invest. Co., No. 16 1:22-cv-1419 JLT SAB, 2023 WL 8675398, at *4 (E.D. Cal. Dec. 15, 2023) (quoting Rutherford 17 v. Nuway Ins. Agency Inc., No. SACV 21-00576-CJC-JDE, 2021 WL 4572008, at *1 (C.D. Cal. 18 Apr. 1, 2021)). Underlying these decisions is “the recent confluence of several California-law rules 19 [that] have combined to create a highly unusual systemic impact on ADA-based Unruh Act cases 20 that clearly threatens to have a significant adverse impact on federal-state comity.” Arroyo, 19 21 F.4th at 1211. 22 Notably, Congress adopted the ADA to address the discrimination encountered by persons 23 with disabilities, providing a private cause of action to seek injunctive, but not monetary, relief. 24 (See id. at 1205) (discussing background and relief available under the ADA). And the Unruh Act 25 likewise prohibits disability discrimination, containing a provision, Cal. Civ. Code § 51(f), stating 26 that a violation of the ADA also violates the Unruh Act. However, unlike the ADA, the Unruh Act 27 allows a plaintiff to recover “up to a maximum of three times the amount of actual damage but in 28 no case less than four thousand dollars.” Cal. Civ. Code § 52(a). 1 In response to perceived abuses of the Unruh Act, California has enacted requirements for 2 bringing such claims, which requirements the Ninth Circuit has assumed, without deciding, “apply 3 only in California state court.” Vo, 49 F.4th at 1170. For example, provisions were added (1) 4 regarding the contents of demand letters, Cal. Civ. Code § 55.31; (2) imposing heightened pleading 5 requirements, Cal. Civ. Code § 425.50(a); and (3) requiring an additional filing fee of $1,000 for 6 so called “high-frequency litigants,” Cal. Gov’t Code § 70616.5(b), see Cal. Civ. Code § 425.55(b) 7 (defining a high-frequency litigant to include “[a] plaintiff who has filed 10 or more complaints 8 alleging a construction-related accessibility violation within the 12-month period immediately 9 preceding the filing of the current complaint alleging a construction-related accessibility 10 violation”). 11 All of these requirements2 apply to claims alleging a construction-related accessibility 12 violation, defined as involving “a provision, standard, or regulation under state or federal law 13 requiring compliance with standards for making new construction and existing facilities accessible 14 to persons with disabilities,” including those related to the ADA. Cal. Civ. Code § 55.52(a)(1), (6); 15 see Cal. Civ.

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Bluebook (online)
Gastelum v. Tilly's, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/gastelum-v-tillys-inc-caed-2025.