Gomez v. Fairwinds Estate Winery, LLC

Background

Andres Gomez filed the action on January 4, 2022, against Fairwinds Estate Winery, LLC. The complaint alleged that the defendant’s website, whose root domain was identified as https://www.fairwindsestatewinery.com/, violated the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act. Gomez sought declaratory and injunctive relief under the ADA, statutory damages under the Unruh Act, and attorney’s fees and costs.

Gomez alleged that the federal court had federal-question jurisdiction over the ADA claim and supplemental jurisdiction over the Unruh Act and other state-law claims. Supplemental jurisdiction is a court’s discretionary authority to hear related state-law claims alongside claims over which it has original federal jurisdiction.

Court’s analysis

The court explained that supplemental jurisdiction is discretionary and may be declined when, among other circumstances, a state-law claim raises complex or predominant state-law issues or when exceptional circumstances provide compelling reasons to decline jurisdiction. The court cited decisions declining supplemental jurisdiction over Unruh Act claims brought with ADA website-accessibility claims.

The court also relied on its reasoning in a recent related case, where it discussed the increase in federal ADA accessibility cases accompanied by Unruh Act claims. The court described concerns that filing such cases in federal court could avoid California’s additional procedural requirements for certain construction-related accessibility claims and could undermine California courts’ role in applying those policies. The court stated that this case presented the same considerations.

Order

The court ordered Gomez to show cause why it should not decline to exercise supplemental jurisdiction over the Unruh Act claim. Gomez was required to file a response within 21 days of the order. The response had to identify the amount of statutory damages sought.

Gomez and his counsel also had to include declarations providing all facts necessary for the court to determine whether they satisfied California’s definition of a “high-frequency litigant” under California Civil Procedure Code sections 425.55(b)(1) and (2). The court stated that failure to file a written response would result in dismissal of the complaint.

This order was an order to show cause. It did not state that the court had already declined supplemental jurisdiction or already dismissed the complaint. Judge Jon S. Tigar signed the order.