Garcia v. A & A Laundry, LLC
- Jon Tigar
- 4:22-cv-01527
- U.S. District Court · Northern District of California
- 3
In Garcia v. A & A Laundry, LLC, Judge Tigar ordered a response explaining why the court should decline jurisdiction over Garcia’s Unruh Act claim.
Orlando Garcia and his counsel must respond and provide the required declarations; A & A Laundry, LLC is affected because the court may later dismiss the complaint or decline to hear the Unruh Act claim.
What happened
In Garcia v. A & A Laundry, LLC, Orlando Garcia alleged that the defendant violated the Americans with Disabilities Act and California’s Unruh Civil Rights Act at a San Francisco laundry. He sought an order requiring access, statutory damages under the Unruh Act, and attorney’s fees and costs.
The court said it was considering whether to refuse to hear Garcia’s state-law Unruh Act claim alongside his federal disability claim. It ordered Garcia to explain why the court should continue hearing that claim, identify the statutory damages he seeks, and provide information about whether he qualifies as a repeat accessibility litigant under California law.
Judge Jon S. Tigar gave Garcia 21 days to respond and required Garcia and his lawyer to submit declarations. The order warns that failing to respond in writing will result in dismissal of the complaint; it does not yet decide whether the court will decline jurisdiction.
The detailed version
- Garcia v. A & A Laundry, LLC · No. 4:22-cv-01527
- Jon Tigar
- May 2, 2022
Background
Orlando Garcia filed this action against A & A Laundry, LLC. He alleged violations of the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act concerning an A & A Laundry Wash & Dry in San Francisco, California. He sought injunctive relief under both statutes, statutory damages under the Unruh Act, and attorney’s fees and costs.
Garcia asserted that the court had federal-question jurisdiction over the ADA claim and supplemental jurisdiction over the Unruh Act and other state-law claims. Supplemental jurisdiction is the court’s discretionary authority to hear related state-law claims together with federal claims.
Court’s analysis
The court explained that federal law allows a district court to decline supplemental jurisdiction in several circumstances, including when exceptional circumstances provide compelling reasons not to hear the state-law claim. The court discussed decisions from other California federal courts that declined to hear Unruh Act claims accompanying ADA accessibility claims.
The court relied particularly on its recent decision in a prior related proceeding, which addressed the increase in federal ADA accessibility cases accompanied by Unruh Act claims seeking statutory damages. The court stated that this pattern could bypass California’s additional procedural requirements for construction-related accessibility claims and undermine California courts’ role in applying the state’s policies. It concluded that this case presented the same considerations.
Order
The court ordered Garcia to show cause—that is, to explain—why it should not decline to exercise supplemental jurisdiction over the Unruh Act claim. Garcia had 21 days from the order to file a response. The response must identify the amount of statutory damages sought. Garcia and his counsel must also submit 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 warned that failure to file a written response will result in dismissal of the complaint. The opinion is an order to show cause, not a final ruling declining jurisdiction or deciding the merits of the ADA or Unruh Act claims.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.