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N.D. Cal.Procedural orderFiled Jan. 3, 2022

Garcia v. Maciel

Judge
Joseph Spero
Docket
3:21-cv-03743
Court
U.S. District Court · Northern District of California
Pages
1
Civil ProcedureADA / Disability
In one sentence

In Garcia v. Maciel, Magistrate Judge Spero ordered Garcia to explain why the court should not decline jurisdiction over his state-law claim.

Who this affects

Orlando Garcia and the defendants, because the order requires Garcia to address whether the court should continue exercising supplemental jurisdiction over his Unruh Act claim.

What happened

Garcia v. Maciel concerns Orlando Garcia’s federal claim under the Americans with Disabilities Act and his state-law claim under California’s Unruh Act. The defendants had moved to dismiss for lack of subject-matter jurisdiction, primarily arguing about standing.

The court ordered Garcia to explain why it should continue hearing the Unruh Act claim if it finds that it has jurisdiction over the federal claim. The order directed Garcia to address this issue in his opposition brief, due January 13, 2022, if any part of the case survives the defendants’ motion.

The court did not decide the defendants’ motion or the claims’ merits. Magistrate Judge Joseph Spero issued an order to show cause concerning whether the court should decline supplemental jurisdiction over the state-law claim.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Garcia v. Maciel · No. 3:21-cv-03743
Judge
Joseph Spero
Date
Jan. 3, 2022

Background

On December 31, 2021, the defendants moved to dismiss the case for lack of subject-matter jurisdiction. The opinion states that the motion primarily addresses standing and does not address supplemental jurisdiction, which is a federal court’s authority to hear related state-law claims alongside a federal claim.

Garcia asserts a federal claim under the Americans with Disabilities Act and a state-law claim under the Unruh Act. The court cited Arroyo v. Rosas, which discussed circumstances in which a court might decline supplemental jurisdiction over an Unruh Act claim if the issue is raised earlier in the case.

Order

The court ordered Orlando Garcia to show cause why, if the court determines that it has subject-matter jurisdiction over his ADA claim, it should not decline to exercise supplemental jurisdiction over his Unruh Act claim. Garcia’s opposition brief, due January 13, 2022, must address why exercising supplemental jurisdiction is appropriate if any portion of the case survives the defendants’ motion.

Disposition and significance

This opinion is an order to show cause, not a decision on the defendants’ motion or on the merits of Garcia’s ADA or Unruh Act claims. Magistrate Judge Joseph Spero required Garcia to address the court’s possible refusal to hear the state-law claim; the opinion does not state that the court ultimately declined jurisdiction or dismissed any claim.

The authoritative version

Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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