Johnson v. Hub's Coffee LLC

Background

Scott Johnson sued Hub's Coffee LLC under the Americans with Disabilities Act (ADA) and California's Unruh Civil Rights Act. He alleged that he encountered barriers involving the sales counters and dining surfaces during visits to Hub's Coffee in San Jose, California, in March and April 2021. The complaint alleged that Hub's Coffee LLC owned the business.

Hub's Coffee LLC moved to dismiss for lack of subject-matter jurisdiction under Rule 12(b)(1). The motion relied on a declaration from Alfredo Fernando, the defendant's managing member, stating that the coffee shop had permanently closed in July 2021 because of a serious downturn in business and that the defendant was defunct because its sole business had been operating the coffee shop.

ADA Claim

Hub's Coffee LLC argued that the permanent closure made Johnson's ADA claim moot, meaning that there was no longer a live dispute for the court to resolve, and that Johnson therefore lacked standing to maintain the claim. Johnson did not dispute that the location had permanently closed. He stated that he would not seek injunctive relief under the ADA for that location, although he said it was unknown whether the business would open another location.

The court stated that a claim may become moot when later events make clear that the alleged conduct cannot reasonably be expected to recur and the effects of the alleged violation have been completely and irrevocably eliminated. The parties agreed that Johnson's ADA claim was moot. The court therefore granted the motion to dismiss that claim.

Unruh Act Claim

After dismissing the ADA claim, the only remaining claim was Johnson's claim under California's Unruh Act. The court had jurisdiction over that state-law claim only through supplemental jurisdiction, which allows a federal court to hear related state-law claims in the same case.

Johnson argued that he could continue with the Unruh Act claim despite the closure and asked the court to keep exercising supplemental jurisdiction. The court declined to do so, explaining that courts in the district had declined to exercise supplemental jurisdiction over Unruh Act claims after dismissing parallel ADA claims. It concluded that continuing to hear the claim would not further judicial economy, convenience, fairness, or comity. The court granted the motion to dismiss the Unruh Act claim.

Disposition

The court granted Defendant's motion to dismiss and directed the Clerk of Court to close the file. The opinion does not state that either dismissal was with or without prejudice.