Gomez v. Huneeus Wines LLC

Background

Andres Gomez filed this action against Huneeus Wines LLC concerning the Flowers Vineyards & Winery website. He alleged violations of the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act. He sought declaratory and injunctive relief under the ADA, statutory damages under the Unruh Act, and attorney’s fees and costs. Gomez 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 federal court’s discretionary authority to hear related state-law claims alongside claims within its original jurisdiction. The court explained that it may decline supplemental jurisdiction when a state-law claim raises complex or novel state-law issues, substantially predominates over the federal claim, the federal claims have been dismissed, or exceptional circumstances provide compelling reasons to decline jurisdiction.

The court relied on its earlier decision in a related case and on decisions discussing the recent increase in California federal cases combining ADA website-accessibility claims with Unruh Act claims seeking statutory damages. Those decisions reasoned that filing such cases in federal court can avoid California’s additional procedural requirements for construction-related accessibility claims and can interfere with California’s policies and the role of its state courts.

Order

The court ordered Gomez to show cause—meaning to explain—why it should not decline supplemental jurisdiction over the Unruh Act claim. Gomez had 21 days from the order to respond and was required to identify the amount of statutory damages sought. Gomez and his counsel also had to submit declarations containing the facts needed to determine whether they meet California’s definition of “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 will result in dismissal of the complaint. Gomez also had to serve the order on Huneeus Wines LLC and file proof of service by May 18, 2022. The order did not decide whether the court would ultimately retain or decline jurisdiction over the Unruh Act claim.