Garcia v. Belen-Bautista
- Vince Chhabria
- 3:22-cv-01613
- U.S. District Court · Northern District of California
- 2
In Garcia v. Belen-Bautista, Judge Chhabria dismissed the Unruh Act claim and directed the defendant to choose discovery or an evidentiary hearing.
The plaintiff’s Unruh Act claim was dismissed after the court declined supplemental jurisdiction. The defendant must choose between three months of jurisdictional discovery and proceeding directly to an evidentiary hearing, with any discovery addressing the plaintiff’s intent to return and whether the plaintiff personally visited the defendant’s establishment.
What happened
In Garcia v. Belen-Bautista, the court declined to continue hearing the plaintiff’s Unruh Act claim under its supplemental jurisdiction. The court said the case was still at an early stage and that keeping the claim would not serve efficiency, convenience, fairness, or respect for state courts.
The court also said the circumstances—including the plaintiff’s alleged status as a frequent filer of Americans with Disabilities Act and Unruh Act claims seeking federal jurisdiction to avoid California’s procedural requirements—were exceptional circumstances allowing it to decline jurisdiction. The order dismissed the Unruh Act claim.
Judge Vince Chhabria ordered the defendant to notify the court within 14 days whether it wanted three months of jurisdictional discovery or preferred to proceed directly to an evidentiary hearing. If discovery is chosen, it may address the plaintiff’s intent to return and whether the plaintiff personally visited the defendant’s establishment.
The detailed version
- Garcia v. Belen-Bautista · No. 3:22-cv-01613
- Vince Chhabria
- June 22, 2022
Ruling
The court declined to exercise supplemental jurisdiction over the plaintiff’s Unruh Act claim and issued an order dismissing that claim. Supplemental jurisdiction is a federal court’s authority to hear a related state-law claim alongside a federal claim. The court relied on the case’s early stage and concluded that judicial economy, convenience, fairness to the litigants, and respect for state courts did not favor retaining jurisdiction.
The court also determined that the facts presented exceptional circumstances for declining jurisdiction. It described the plaintiff as “a frequent filer of ADA and Unruh Act claims seeking federal jurisdiction to circumvent California’s procedural barriers to such suits.” The order did not decide the underlying merits of the Unruh Act claim.
Next Step Ordered by the Court
The defendant must notify the court within 14 days whether it wants a three-month period of jurisdictional discovery or instead wants to proceed directly to an evidentiary hearing. If the defendant chooses discovery, it may take discovery concerning the plaintiff’s intent to return and whether the plaintiff personally visited the defendant’s establishment in the first place.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.