Johnson v. Camarena

Background Scott Johnson sued John A. Camarena and Suzanne Jo Camarena, alleging violations of the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act concerning a Dairy Queen restaurant in Campbell, California. He sought an injunction under both statutes, statutory damages under the Unruh Act, and attorney’s fees and costs. He asserted that the court had federal-question jurisdiction over the ADA claim and supplemental jurisdiction over the Unruh Act and other state-law claims.

Court’s concern about supplemental jurisdiction Supplemental jurisdiction is a federal court’s discretionary authority to hear related state-law claims together with a federal claim. The court explained that it may decline that authority when, among other circumstances, a state-law issue is novel or complex, the state claim substantially predominates, or exceptional circumstances provide compelling reasons to decline jurisdiction.

The court relied on its recent decision in a related accessibility case and on decisions from other federal courts in California. Those decisions discussed the increased number of cases combining ADA accessibility claims with Unruh Act claims seeking statutory damages, as well as California’s additional procedural requirements for construction-related accessibility claims. The court stated that allowing these claims to proceed in federal court can undermine California’s reforms and the role of California state courts. It concluded that this case presented the same considerations.

Order The court did not decide the merits of Johnson’s ADA or Unruh Act claims in this order. Instead, Judge Jon S. Tigar ordered Johnson to show cause—meaning to explain—why the court should not decline to exercise supplemental jurisdiction over the Unruh Act claim. Johnson must file a response within 21 days of the order.

The response must identify the amount of statutory damages sought. Johnson and his counsel must also submit declarations providing all facts needed to determine whether they meet California’s definition of a “high-frequency litigant” under California Civil Procedure Code sections 425.55(b)(1) and (2). The order states that failure to file a written response will result in dismissal of the complaint.