Afifi v. House

Background

Sabrina Afifi sued Hayatt House. The opinion identifies the defendant as Hyatt Corporation doing business as Hyatt House San Ramon, and says it was mistakenly sued as Hayatt House. Afifi alleged that, during a routine transaction at Hyatt House San Ramon, staff made derogatory and class-based assumptions about her, including calling her “ghetto” and implying that she was financially unstable and likely to commit fraud.

Afifi asserted claims under 42 U.S.C. § 1981 for discrimination in contracting and Title II of the Civil Rights Act of 1964 for discrimination in a public accommodation. She also asserted several state-law claims, including claims under California law, negligent hiring, training, or supervision, breach of the implied covenant of good faith and fair dealing, and defamation. The defendant moved to dismiss the entire action for failure to state a claim. Afifi did not respond to the motion.

Federal discrimination claims

The court applied Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not allege enough facts to support a legally recognized claim. The court said that Afifi’s first two claims were the only claims supporting federal-question jurisdiction.

For the Section 1981 claim, the court explained that the law prohibits intentional discrimination based on race in making or enforcing contracts. It requires a plaintiff to allege, among other things, that race was the reason for the contractual harm. The court found that Afifi alleged mistreatment based on perceived financial instability, socioeconomic status, and class—not because of her race. It therefore dismissed the Section 1981 claim.

For the Title II claim, the court explained that the statute protects equal access to public accommodations without discrimination based on race, color, religion, or national origin. The court found that Afifi likewise alleged discrimination based on socioeconomic status or perceived poverty, rather than one of those legally protected categories. It therefore dismissed the Title II claim.

State-law claims and disposition

Because the federal claims were not adequately stated, the court declined to exercise supplemental jurisdiction over the remaining state-law claims. Supplemental jurisdiction is a court’s authority to hear related state-law claims alongside federal claims.

Judge Araceli Martinez-Olguin granted the motion to dismiss and dismissed the complaint with leave to amend. Afifi may file an amended complaint within 30 days that addresses the deficiencies identified in the order. She may not add new claims or parties without the court’s permission or the defendant’s agreement, and she may not incorporate the earlier complaint by reference. The order states that failing to file a compliant amended complaint on time will result in dismissal of the case.