Gomez v. Reynolds Creative Products, Inc.
- Jon Tigar
- 4:22-cv-00830
- U.S. District Court · Northern District of California
- 3
In Gomez v. Reynolds Creative Products, Inc., Judge Tigar ordered a response explaining why the federal court should not decline supplemental jurisdiction over the Unruh Act claim.
Andres Gomez and Reynolds Creative Products, Inc. Gomez and his counsel must respond within 21 days and provide the required damages information and declarations; the complaint may be dismissed if no written response is filed.
What happened
Andres Gomez sued Reynolds Creative Products, Inc., alleging that the Reynolds Family Winery website violated the Americans with Disabilities Act and California’s Unruh Civil Rights Act. He seeks an order requiring changes, statutory damages, and attorney’s fees and costs.
The court questioned whether it should hear the Unruh Act claim alongside the federal disability claim. It ordered Gomez to explain within 21 days why the court should not decline supplemental jurisdiction, identify the statutory damages sought, and provide information about whether he qualifies as a high-frequency litigant under California law.
Judge Tigar warned that failing to file a written response will result in dismissal of the complaint. The order did not yet decide whether the court would keep or dismiss the Unruh Act claim, or whether the underlying allegations were valid.
The detailed version
- Gomez v. Reynolds Creative Products, Inc. · No. 4:22-cv-00830
- Jon Tigar
- Apr. 29, 2022
Background
Andres Gomez filed this action against Reynolds Creative Products, Inc. He alleges violations of the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act relating to the Reynolds Family Winery website. Gomez seeks declaratory and injunctive relief under the ADA, statutory damages under the Unruh Act, and attorney’s fees and costs.
The complaint asserts federal-question jurisdiction over the ADA claim and supplemental jurisdiction over the Unruh Act and other state-law claims. Supplemental jurisdiction is the federal court’s discretionary authority to hear related state-law claims together with federal claims.
Order to Show Cause
The court explained that federal courts may decline supplemental jurisdiction when a state-law claim raises novel or complex issues, substantially predominates over the federal claim, all federal claims have been dismissed, or exceptional circumstances provide compelling reasons to decline jurisdiction.
The court discussed decisions declining supplemental jurisdiction over similar Unruh Act claims brought with ADA claims. Those decisions relied on concerns that filing such cases in federal court could avoid California’s additional procedural requirements for construction-related accessibility claims and interfere with California courts’ role in applying those requirements. The court stated that this case presented the same considerations as an earlier related proceeding and similar cases.
Ruling and Required Response
The court ordered Gomez to show cause—that is, to explain—why it should not decline to exercise supplemental jurisdiction over the Unruh Act claim. Gomez must respond within 21 days of the order. His response must identify the amount of statutory damages sought. Gomez and his counsel must also include declarations providing the facts needed to determine whether they satisfy California’s definition of a “high-frequency litigant” under California Civil Procedure Code sections 425.55(b)(1) and (2).
The court did not state that it was dismissing the complaint at this stage. It stated that failure to file a written response will result in dismissal of the complaint. The order does not decide the merits of Gomez’s ADA or Unruh Act allegations.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.