Whitaker v. Ben Bridge-Jeweler, Inc.
- Edward Davila
- 5:21-cv-00808
- U.S. District Court · Northern District of California
- 6
In Whitaker v. Ben Bridge-Jeweler, Judge Davila granted the defendant’s request to decline supplemental jurisdiction over Whitaker’s Unruh Act claim.
Brian Whitaker’s California Unruh Civil Rights Act claim was affected; the court declined to exercise supplemental jurisdiction over that claim, while the opinion did not decide the merits of the Americans with Disabilities Act claim.
What happened
In Whitaker v. Ben Bridge-Jeweler, Inc., Brian Whitaker alleged that he encountered inaccessible counters at Ben Bridge-Jeweler’s store and asserted claims under the Americans with Disabilities Act and California’s Unruh Civil Rights Act.
Ben Bridge-Jeweler asked the court not to decide the Unruh Act claim under supplemental jurisdiction, which allows a federal court to hear a related state-law claim. The court explained that California imposes special pleading and filing-fee requirements on certain accessibility lawsuits, including those brought by high-frequency litigants, and that federal filing could avoid those restrictions.
Judge Edward Davila granted the defendant’s request and declined to exercise supplemental jurisdiction over the Unruh Act claim. The opinion did not decide the underlying accessibility allegations or the merits of the Americans with Disabilities Act claim.
The detailed version
- Whitaker v. Ben Bridge-Jeweler, Inc. · No. 5:21-cv-00808
- Edward Davila
- Mar. 18, 2022
Background
Brian Whitaker alleged that he has physical disabilities, including a C-4 spinal cord injury, quadriplegia, and reliance on a wheelchair for mobility. He alleged that, during a January 2021 visit to Ben Bridge-Jeweler’s store in Santa Clara, California, he encountered counters that did not comply with accessibility standards. He brought claims under the Americans with Disabilities Act and California’s Unruh Civil Rights Act.
Motion and legal standard
Ben Bridge-Jeweler moved for the court to decline supplemental jurisdiction over the Unruh Act claim. Supplemental jurisdiction is a federal court’s authority to hear a related state-law claim alongside a federal claim. Under 28 U.S.C. § 1367(c), a court may decline that jurisdiction in specified circumstances, including when exceptional circumstances and compelling reasons support doing so.
Court’s analysis
The court discussed California laws imposing heightened pleading requirements, verification requirements, additional allegations, and an extra filing fee on certain construction-related accessibility claims. The court found that Whitaker fell within California’s definition of a high-frequency litigant. It reasoned that allowing claims like this to proceed in federal court through supplemental jurisdiction could permit plaintiffs to avoid California’s restrictions and could require the federal court to disregard interests that California considered important. The court also relied on the early stage of the case and the burden created by the increasing number of similar Americans with Disabilities Act and Unruh Act cases.
The court adopted the reasoning of a cited 2019 decision involving an earlier round of Whitaker’s litigation. It concluded that exceptional circumstances and compelling reasons justified declining supplemental jurisdiction over the Unruh Act claim.
Disposition
Judge Edward Davila granted the defendant’s request to decline supplemental jurisdiction over the Unruh Act claim. The opinion did not decide the merits of Whitaker’s accessibility allegations or his Americans with Disabilities Act claim. The opinion contains an apparent clerical inconsistency: one sentence says the court grants “Plaintiff’s motion,” while the surrounding discussion and the conclusion identify and grant the defendant’s request.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.