Garcia v. Aljamal
- Vince Chhabria
- 3:21-cv-06541
- U.S. District Court · Northern District of California
- 1
In Garcia v. Aljamal, Judge Chhabria dismissed the Unruh Act claim after declining supplemental jurisdiction because the case was early and raised exceptional circumstances.
Orlando Garcia’s Unruh Act claim against Mosleh A. Aljamal was dismissed after the court declined supplemental jurisdiction.
What happened
Garcia v. Aljamal involved Orlando Garcia’s claim under California’s Unruh Civil Rights Act against Mosleh A. Aljamal. The order addressed only that claim.
The court declined to keep the claim in federal court under supplemental jurisdiction, which allows a federal court to hear certain related state-law claims. It relied on the case’s early stage and on circumstances the court described as involving frequent ADA and Unruh Act filings used to avoid California procedural barriers.
The court dismissed the Unruh Act claim. Judge Vince Chhabria signed the order on June 23, 2022. The order does not state whether the dismissal was with or without prejudice.
The detailed version
- Garcia v. Aljamal · No. 3:21-cv-06541
- Vince Chhabria
- June 23, 2022
Background
Orlando Garcia sued Mosleh A. Aljamal. The order concerns Garcia’s claim under California’s Unruh Civil Rights Act. The opinion refers to ADA and Unruh Act claims, but this order specifically addresses the Unruh Act claim.
Court’s reasoning
The court declined to exercise supplemental jurisdiction over the Unruh Act claim. Supplemental jurisdiction is the authority to hear a related state-law claim alongside a federal claim. Citing Ninth Circuit precedent, the court said the case was in its early stages, so judicial economy, convenience, fairness to the litigants, and respect for state courts did not favor retaining jurisdiction.
The court also relied on what it described as the case’s circumstances: a frequent filer of ADA and Unruh Act claims seeking federal jurisdiction to circumvent California’s procedural barriers to those suits. The court stated that these circumstances were the type contemplated by 28 U.S.C. § 1367(c)(4), which permits a federal court to decline supplemental jurisdiction in exceptional circumstances.
Ruling
The court ordered dismissal of the Unruh Act claim. The order does not state whether the dismissal was with or without prejudice, and it does not describe any ruling on the merits of the claim.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.