Johnson v. Camino Group LLC

Background

Scott Johnson filed this action against Camino Group LLC and Ivy Valero Auto Service, Inc. He alleged violations of the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act concerning Ivy & Truman Automotive in Sunnyvale, California. He sought injunctive relief under both statutes, statutory damages under the Unruh Act, and attorney’s fees and costs. Johnson alleged 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 Analysis

Supplemental jurisdiction is the authority to hear state-law claims related to claims within the court’s original federal jurisdiction. The court explained that this authority is discretionary and may be declined when, among other circumstances, a state-law claim substantially predominates or exceptional circumstances provide compelling reasons to decline jurisdiction.

The court discussed decisions declining supplemental jurisdiction over Unruh Act claims brought alongside ADA accessibility claims. It cited concerns that the relative ease of filing these combined claims in federal court could allow plaintiffs to avoid California’s additional procedural requirements for construction-related accessibility claims. The court also relied on its recent decision in a similar case, which found extraordinary circumstances and compelling reasons to decline supplemental jurisdiction after considering judicial economy, convenience, fairness, and respect for state courts.

Order

The court did not yet rule that it would decline jurisdiction or dismiss the complaint. Instead, it ordered Johnson to show cause—meaning to explain—why the court should not decline supplemental jurisdiction over the Unruh Act claim. Johnson was required to file a response within 21 days of the order and identify the amount of statutory damages sought. Johnson and his counsel were also required to include declarations containing the facts necessary for the court to determine whether they satisfied the 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 would result in dismissal of the complaint. The order was signed by Jon S. Tigar, United States District Judge.