Gilbert v. Alsamiri

District Court, E.D. California·Decided August 16, 2023·No. 1:22-cv-00481·Unknown

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 DARREN GILBERT, Case No. 1:22-cv-00481-JLT-HBK 12 Plaintiff, FINDINGS AND RECOMMENDATION TO DECLINE SUPPLEMENTAL JURISDICTION 13 v. OVER PLAINTIFF’S UNRUH ACT AND HEALTH AND SAFETY CODE CLAIMS 14 ABDO M. ALSAMIRI and TALAL A. OBAID, dba Obaid Smoke Shop Plus, FOURTEEN-DAY OBJECTION PERIOD 15 Defendants. 16 17 18 On April 24, 2022, Plaintiff Darren Gilbert commenced this action by filing a complaint 19 against Defendants Abdo M. Alsamiri and Talal A. Obaid, doing business as Obaid Smoke Shop 20 Plus (collectively “Defendants”), alleging violations of Title III of the Americans with 21 Disabilities Act (“ADA”), 42 U.S.C. §§ 12101 et seq (Count I); the California Unruh Act, 22 California Civil Code § 51 et seq. (Count II); and California Health & Safety Code §§ 19955, 23 19959 (Count III). (Doc. No. 1, “Complaint”). Plaintiff seeks an award of statutory damages, 24 costs of suit, attorney’s fees, litigation expenses, injunctive or preventative relief, and interest at 25 the legal rate from the date of filing of the Complaint. (Id. At 8). Plaintiff, noting this Court has 26 original jurisdiction over the ADA claims, seeks to have this Court exercise supplemental 27 jurisdiction over Plaintiff’s state law Unruh Act Claim and the California Health & Safety Code 28 claim. (Id. at 2). 1 On December 19, 2022, Plaintiff filed a motion for default judgment. (Doc. No. 9). On 2 March 13, 2023, the undersigned ordered Plaintiff to show cause, within fourteen days, why the 3 undersigned should recommend the district court exercise supplemental jurisdiction over 4 Plaintiff’s Unruh Act Claim (Count II) and Health and Safety Code claim (Count III). (Doc. No. 5 11). Plaintiff was also ordered to include with his response declarations from both Plaintiff and 6 Plaintiff’s counsel, signed under the penalty of perjury, that include all facts necessary for the 7 Court to determine whether each is a “high frequency litigant.” (Id.). The undersigned warned 8 Plaintiff that a failure to respond to the March 13, 2023 Order would be deemed a non-opposition 9 to the undersigned recommending the district court decline to exercise supplemental jurisdiction 10 over Plaintiff’s related state law claims. (Id.). Plaintiff filed no response to the Court’s March 11 13, 2023 Order to Show Cause and the time to do so has expired. See docket. For the reasons set 12 forth below, the undersigned recommends the District Judge decline to exercise supplemental 13 jurisdiction over Plaintiff’s Unruh Act and Health and Safety Code claims. 14 APPLICABLE LAW 15 A district court presiding over a civil action in which it has original jurisdiction “shall 16 have supplemental jurisdiction over all other claims that are so related to claims in the action 17 within such original jurisdiction that they form part of the same case or controversy under Article 18 II of the United States Constitution.” 28 U.S.C. § 1367(a). Nonetheless, a district court may 19 decline to exercise supplemental jurisdiction over a claim if: 20 (1) the claim raises a novel or complex issue of State law, 21 (2) the claim substantially predominates over the claim or claims over which the district court has original jurisdiction, 22 (3) the district court has dismissed all claims over which it has 23 original jurisdiction, or 24 (4) in exceptional circumstances, there are other compelling reasons for declining jurisdiction. 25 26 28 U.S.C. § 1367(c). 27 “[P]endent jurisdiction is a doctrine of discretion, not of plaintiff’s right.” United Mine 28 Workers v. Gibbs, 383 U.S. 715, 726 (1996). A district court conducts a two-part inquiry when 1 evaluating whether to exercise supplemental jurisdiction under § 1367(c)(4). Arroyo Jr. v. Rosas, 2 19 F.4th 1202, 1210 (9th Cir. 2021). First, the court “must ‘articulate why the circumstances of 3 the case are exceptional’ within the meaning of § 1367(c)(4).” Id. (quoting Executive Software N. 4 Arm., Inc. v. U.S. Dist. Ct., 24 F.3d 1545, 1558 (9th Cir. 1994)) (other citation omitted). Second, 5 the court must provide compelling reasons to decline jurisdiction by weighing the principles of 6 judicial economy, convenience, fairness, and comity, “‘which underlie the pendent jurisdiction 7 doctrine’ articulated in [United Mine Workers v.] Gibbs.” Id. (quoting City of Chicago v. 8 International Coll. of Surgeons, 522 U.S. 156, 172-73 (1997)) (citing Acri v. Varian Assocs., Inc., 9 144 F.3d 999, 1001 (9th Cir. 1997) (en banc) (referring to these four factors as the “Gibbs 10 values.”)). Courts only need to “‘articulate why the circumstances of the case are exceptional in 11 addition to inquiring whether the balance of the Gibbs values provides compelling reasons for 12 declining jurisdiction in such circumstances.’” Id. at 1211 (quoting Executive Software, 24 F.3d 13 at 1558) (bracket omitted). 14 The Ninth Circuit affirmed a district court’s finding of “extraordinary circumstances” and 15 “compelling reasons” to decline supplemental jurisdiction under the Unruh Act over accessibility 16 related discrimination claims for high frequency litigators. See Vo v. Choi, 49 F. 4th 1167, 1174 17 (9th Cir. 2022); see also Arroyo, 19 F.4th at 1206 (finding “extraordinary circumstances”). 18 Significant to the courts’ decisions were the additional filing and heightened pleading 19 requirements California law imposes on high frequency litigators. Vo, 49 F. 4th at 1172-74; 20 Arroyo, 19 F. 4 1211-14. 21 The same additional filing and heightened pleading requirements are not limited to claims 22 under the Unruh Act but also apply to other statutes for “construction-related accessibility 23 claims.” Arroyo, 19 F.4th at 1206; see also Cal. Proc. Civ. Code § 425.50(a); Cal. Civ. Code § 24 55.2. A “construction-related accessibility standard” means “a provision, standard, or regulation 25 under state or federal law requiring compliance with standards for making new construction and 26 existing facilities accessible to people with disability, including, but not limited to, any provision, 27 standard, or regulation set forth in [Cal. Civ. Code §] 51 . . . [Cal. Health and Safety Code §] 28 19955.5 . . . the federal [ADA] . . ..” Cal. Civ. Code. § 55.52 (a)(6). Both §§ 19955 and 19959 1 were enacted to safeguard that certain facilities are accessible to disabled individuals and § 2 19955.5 is expressly included as subject to the “construction-related accessibility standard.” 3 ANALYSIS 4 Here, the first prong of the two-part § 1367(c) inquiry is satisfied because exceptional 5 circumstances exist. Supra, the Ninth Circuit already acknowledged that California’s heightened 6 pleading requirements imposed on high frequency litigants who allege construction-related 7 accessibility violations satisfies exceptional circumstances. See Vo, 49 F. 4th at 1172-74; Arroyo, 8 19 F. 4 1211-14. A high frequency litigant subject to the heightened pleading requirements is 9 defined under California law as: 10 A plaintiff who has filed 10 or more complaints alleging a construction-related accessibility violation within the 12-month 11 period immediately preceding the filing of the current complaint alleging a construction-related accessibility violation. 12 13 Cal.

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