Johnson v. Bhakta
- Vince Chhabria
- 3:22-cv-01902
- U.S. District Court · Northern District of California
- 1
In Johnson v. Bhakta, Judge Chhabria dismissed Scott Johnson’s Unruh Act claim after declining jurisdiction because the case was early and presented exceptional circumstances.
Scott Johnson’s Unruh Act claim was dismissed; the opinion does not state the disposition of any other claims.
What happened
In Johnson v. Bhakta, the court considered whether to keep hearing Scott Johnson’s claim under California’s Unruh Civil Rights Act, which was related to the federal case.
The court declined to keep jurisdiction over that state-law claim because the case was in its early stages. It also found that the circumstances described in the opinion—including Johnson’s alleged frequent filing of Americans with Disabilities Act and Unruh Act claims to obtain federal jurisdiction—supported declining jurisdiction.
The court dismissed the Unruh Act claim. Judge Vince Chhabria signed the order on June 22, 2022.
The detailed version
- Johnson v. Bhakta · No. 3:22-cv-01902
- Vince Chhabria
- June 22, 2022
Background
Scott Johnson brought a case against Arvind Bhakta and others that included a claim under California’s Unruh Civil Rights Act. The opinion addresses whether the federal court should continue exercising supplemental jurisdiction—the authority to hear a related state-law claim along with a federal claim—over the Unruh Act claim.
Court’s reasoning
The court declined to exercise supplemental jurisdiction under 28 U.S.C. § 1367(c)(4). It explained that the case was in its early stages, so judicial economy, convenience, fairness to the parties, and respect for state courts did not favor keeping the claim in federal court. The court also stated that the facts presented the type of exceptional circumstances contemplated by the statute, describing Johnson as “a frequent filer of ADA and Unruh Act claims seeking federal jurisdiction to circumvent California’s procedural barriers to such suits.”
Disposition
The order dismissed the Unruh Act claim. The opinion does not state whether the dismissal was with or without prejudice, and it does not describe the disposition of any other claims.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.