Gomez v. Raymond Vineyard & Cellar, Incorporated

Background

Andres Gomez filed the action on December 20, 2021, against Raymond Vineyard & Cellar, Incorporated. He alleged that the defendant’s website, whose root domain is https://raymondvineyards.com, violated the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act. Gomez seeks declaratory and injunctive relief under the ADA, statutory damages under the Unruh Act, and attorney’s fees and costs.

Gomez asserted federal-question jurisdiction over the ADA claim and supplemental jurisdiction over the Unruh Act and other state-law claims. Supplemental jurisdiction is a federal court’s discretionary authority to hear related state-law claims along with claims that are within the court’s original jurisdiction.

Court’s analysis

The court explained that federal courts may decline supplemental jurisdiction when, among other circumstances, a state-law claim substantially predominates over the federal claim or exceptional circumstances provide compelling reasons to decline jurisdiction. The court relied on its recent decision in a similar case and on decisions discussing the increase in federal ADA website-accessibility cases accompanied by Unruh Act claims seeking statutory damages.

Those decisions described California’s additional procedural requirements for certain construction-related accessibility claims and concerns that filing such cases in federal court can avoid those requirements and undermine California’s policies and the role of its state courts. The court concluded that this case presented the same considerations.

Order

The court ordered Gomez to show cause—meaning to explain—why it should not decline to exercise supplemental jurisdiction over the Unruh Act claim. Gomez must file a response within 21 days of the order, identify the amount of statutory damages sought, and provide a declaration containing all facts necessary to determine whether he qualifies as a “high-frequency litigant” under California Civil Procedure Code sections 425.55(b)(1) and (2). Gomez’s counsel must also include a declaration with the required information.

The court did not state that it was dismissing the complaint or the Unruh Act claim in this order. It warned, however, that failure to file a written response will result in dismissal of the complaint. The order was signed by Judge Jon S. Tigar.