Garcia v. Maciel

Background

Orlando Garcia asserted two claims involving alleged accessibility barriers at a business: a federal claim under the Americans with Disabilities Act (ADA) and a state-law claim under California’s Unruh Civil Rights Act. The Unruh Act claim incorporated the ADA’s substantive accessibility requirements but provided statutory damages. The defendants had filed a motion to dismiss the ADA claim, and the court had scheduled an evidentiary hearing concerning the credibility of Garcia’s stated intent to return to the business.

The court had ordered Garcia to explain why it should not decline supplemental jurisdiction over the Unruh Act claim. Supplemental jurisdiction is a federal court’s authority to hear a related state-law claim together with a federal claim. Garcia argued that the court should retain the state claim, including because he believed he had already provided information sought by California’s heightened pleading requirements and because the court’s procedures for ADA-access cases served similar goals.

Reasoning

The court relied on the Ninth Circuit’s decision in a prior related proceeding, which identified exceptional circumstances under 28 U.S.C. § 1367(c)(4). That decision described an unusual interaction between the Unruh Act’s damages remedy and California’s heightened procedural requirements for certain disability-access lawsuits. The Ninth Circuit concluded that retaining supplemental jurisdiction over ADA-based Unruh Act claims could undermine California’s reforms and interfere with the relationship between federal and state courts.

The court found those concerns applicable here. It noted that Garcia had personally filed more than three hundred cases in the district since the beginning of the preceding year, as reflected in the court’s electronic filing system. It also concluded that the record did not show that Garcia’s deposition supplied all information required by California law. Because the ADA claim had not yet been fully adjudicated, the court determined that requiring the Unruh Act claim to proceed in state court would not be pointless. The court concluded that respect for California’s policy choices outweighed concerns about judicial economy and efficiency, and that fairness also favored declining jurisdiction.

Ruling

The court declined to exercise supplemental jurisdiction over Garcia’s Unruh Act claim and dismissed that claim without prejudice to pursuing it in state court. The order did not resolve the defendants’ motion to dismiss the ADA claim. Instead, Judge Joseph C. Spero continued the evidentiary hearing to March 4, 2022, and ordered Garcia by February 18, 2022, either to file a motion or stipulation dismissing the ADA claim or to submit a status report stating that he wished to proceed with it in federal court. If he chose to proceed, he was required to appear at the hearing prepared to testify under oath.