Doe 1400 v. Stanford Health Care

Background

Doe #1400 sued Stanford Health Care in the Superior Court of California for the County of Santa Clara. The complaint and later amended versions sought money damages and civil penalties under California’s Unruh Civil Rights Act. Stanford Health Care removed the action to federal court, asserting that the case arose under the Americans with Disabilities Act and Section 504 of the Rehabilitation Act of 1973.

After the court denied an earlier motion to remand, Doe #1400 asked for permission to file a corrected second amended complaint and renewed the request to return the case to state court. The proposed corrected complaint removed references to the Americans with Disabilities Act, the Rehabilitation Act, the Affordable Care Act, and the Health Insurance Portability and Accountability Act. It instead relied on California’s Unruh Civil Rights Act, California Government Code section 11135, and California’s Disabled Persons Act.

Motion to Amend

The court applied Federal Rule of Civil Procedure 15(a), under which permission to amend generally should be freely given unless factors such as undue delay, bad faith, repeated failure to fix defects, unfair prejudice, or futility weigh against amendment.

Stanford Health Care argued that Doe #1400 had repeatedly amended the complaint, acted in bad faith to obtain a preferred forum, and caused prejudice by making the allegations a “moving target.” The court rejected those arguments. It found no undue delay, credited Doe #1400’s explanation that the federal claims were removed to pursue the case in state court, and concluded that the amendment efforts were not unacceptably numerous in light of the plaintiff’s self-represented status. The court also found no undue prejudice or futility. It therefore granted the motion for leave to file the Corrected Second Amended Complaint.

Motion to Remand

A remand sends a case from federal court back to state court. The court explained that federal-question jurisdiction generally depends on whether a federal claim appears on the face of the plaintiff’s properly pleaded complaint.

The court found that the corrected complaint removed all federal claims. It rejected Stanford Health Care’s argument that the Unruh Act claim was necessarily a federal claim because it was allegedly based on a violation of federal law. The court explained that a federal-law violation may be one route to liability under the Unruh Act, but it is not a necessary element of that state-law claim. Because the corrected complaint did not present a federal question, the court concluded that it lacked subject-matter jurisdiction over the amended action and granted the motion to remand. The action was remanded to the Superior Court of California for the County of Santa Clara.

Motion to Seal

Doe #1400 asked the court to seal the entire federal record to protect the plaintiff’s anonymity. The court found that the plaintiff had not provided specific, compelling reasons to seal the entire record. It nevertheless concluded that protecting the plaintiff’s anonymity justified sealing documents whose docket tabs contained identifying information.

The court granted in part and denied in part the motion to seal. It ordered Docket Nos. 1, 2, 6, and 7 sealed, but did not seal the entire record.

Motion to Shorten Time and Request for Legal Advice

Doe #1400 submitted two filings that the court treated as a motion to shorten the time for a hearing and a request for legal advice about California Code of Civil Procedure section 367.3 and possible sanctions. Because the other motions resolved the scheduled hearings, the motion to shorten time was moot. The court also stated that federal courts do not provide legal advice or act as counsel for self-represented litigants.

The court denied the motion to shorten time and request for legal advice. The order does not decide the merits of Doe #1400’s underlying state-law claims.