Love v. Shops at Tanforan Associates, LLC

Background

Samuel Love brought claims under the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act. He alleged that Defendants failed to provide accessible sales counters at Regis Salon in San Bruno, California.

Motion and Arguments

Defendants moved to dismiss. They argued that the ADA claim was moot because the company that owned Regis Salon had ceased operating and the salon had permanently closed on January 2, 2020. According to Defendants, no effective relief remained available because the ADA relief at issue was injunctive relief, meaning a court order requiring or prohibiting future conduct. Defendants also argued that the court should decline supplemental jurisdiction over the remaining state-law claim. Supplemental jurisdiction is a federal court’s discretionary authority to hear related state-law claims alongside federal claims.

Love did not dispute that his ADA claim was moot. He asked the court to continue exercising supplemental jurisdiction over his Unruh Act claim.

Ruling

The court stated that federal courts may decline supplemental jurisdiction after all federal claims have been dismissed, considering judicial economy, convenience, fairness, and respect for state courts. Because the federal claim had become moot early in the case and only the state-law claim remained, the court declined to exercise supplemental jurisdiction.

Judge Joseph C. Spero granted Defendants’ motion and dismissed the case without prejudice. The court also vacated the motion hearing set for March 6, 2020.