Johnson v. 3375 Camino City Square LLC
- Jon Tigar
- 4:21-cv-06672
- U.S. District Court · Northern District of California
- 3
In Johnson v. 3375 Camino City Square LLC, Judge Tigar ordered a response on supplemental jurisdiction over the Unruh Act claim, warning nonresponse could dismiss the complaint.
Scott Johnson and his counsel, who were ordered to respond within 21 days and provide information about damages and high-frequency-litigant status.
What happened
Johnson v. 3375 Camino City Square LLC concerns Scott Johnson’s claims that Tiranga Super Market violated the Americans with Disabilities Act and California’s Unruh Civil Rights Act. He sought an injunction, statutory damages, attorney’s fees, and costs.
The court questioned whether it should hear the state-law Unruh Act claim along with the federal disability claim. It cited concerns that similar cases could avoid California’s additional requirements for disability-access claims and concluded that the case raised the same concerns as other cases where federal courts declined to hear such state-law claims.
The court ordered Johnson to explain within 21 days why it should not decline supplemental jurisdiction over the Unruh Act claim. Judge Tigar also required Johnson and his counsel to identify the statutory damages sought and provide information about whether they qualify as high-frequency litigants; failure to respond in writing would result in dismissal of the complaint.
The detailed version
- Johnson v. 3375 Camino City Square LLC · No. 4:21-cv-06672
- Jon Tigar
- Apr. 22, 2022
Background
Scott Johnson sued 3375 Camino City Square LLC over conditions at Tiranga Super Market in Santa Clara, California. The complaint alleged violations of the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act (Unruh Act). Johnson sought injunctive relief under both statutes, statutory damages under the Unruh Act, and attorney’s fees and costs. He asserted federal-question jurisdiction over the ADA claim and supplemental jurisdiction over the Unruh Act and other state-law claims.
Court’s Analysis
Supplemental jurisdiction is the court’s discretionary authority to hear related state-law claims alongside federal claims. The court explained that it 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 decisions declining supplemental jurisdiction over Unruh Act claims filed alongside ADA claims. It discussed the recent increase in these cases and the concern that filing them in federal court could avoid California’s additional procedural requirements for construction-related accessibility claims. The court stated that these circumstances were extraordinary and that the same considerations applied here.
Order
The court ordered Johnson to show cause—that is, to explain—why it should not decline supplemental jurisdiction over the Unruh Act claim. Johnson had to file a response within 21 days of the order. The response had to identify the amount of statutory damages sought. Johnson and his counsel also had to submit declarations containing the facts needed to determine whether they met California’s definition of a “high-frequency litigant.” The order stated that failure to file a written response would result in dismissal of the complaint. The opinion did not state that the court had already declined jurisdiction or dismissed the complaint. Judge Jon S. Tigar signed the order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.