Arroyo, Jr. v. L.F. George Properties Corp.
- Vince Chhabria
- 3:21-cv-08701
- U.S. District Court · Northern District of California
- 2
In Arroyo, Jr. v. L.F. George Properties Corp., Judge Chhabria dismissed the Unruh Act claim and ordered defendant to choose discovery or a hearing.
Rafael Arroyo, Jr.’s Unruh Act claim was dismissed. The defendants are affected by the order requiring the defendant to choose between three months of jurisdictional discovery and a direct evidentiary hearing.
What happened
In Rafael Arroyo, Jr. v. L.F. George Properties Corp., the court considered whether to keep a California Unruh Civil Rights Act claim in federal court.
The court declined to continue handling that claim because the case was at an early stage and exceptional circumstances weighed against supplemental jurisdiction. The court also described Arroyo as a frequent filer of Americans with Disabilities Act and Unruh Act claims seeking federal jurisdiction to avoid California procedural barriers.
Judge Vince Chhabria dismissed the Unruh Act claim. The defendant must tell the court within 14 days whether it wants three months of jurisdiction-related discovery about Arroyo’s intent to return and whether he personally visited the defendant’s establishment, or prefers to proceed directly to an evidentiary hearing.
The detailed version
- Arroyo, Jr. v. L.F. George Properties Corp. · No. 3:21-cv-08701
- Vince Chhabria
- June 22, 2022
Background
Rafael Arroyo, Jr. sued L.F. George Properties Corp. and other defendants, including a claim under California’s Unruh Civil Rights Act. The opinion refers to Arroyo as a frequent filer of claims under the Americans with Disabilities Act and the Unruh Act who seeks federal jurisdiction to avoid California procedural barriers to those suits.
Ruling on the Unruh Act Claim
The court declined to exercise supplemental jurisdiction over the Unruh Act claim. Supplemental jurisdiction is a federal court’s authority to hear certain state-law claims connected to claims within its federal jurisdiction. The court stated that the case was in its early stages, so judicial economy, convenience, fairness, and respect for state courts did not favor retaining the claim. It also found that the circumstances described in the opinion were the type of exceptional circumstances allowing the court to decline supplemental jurisdiction under 28 U.S.C. § 1367(c)(4).
The order dismissed the Unruh Act claim. It does not state whether the dismissal was with or without prejudice.
Next Step Ordered
The defendant must notify the court within 14 days whether it wants a three-month period of jurisdictional discovery or would rather proceed directly to an evidentiary hearing. If the defendant chooses discovery, it may seek information about Arroyo’s intent to return and whether he personally visited the defendant’s establishment.
Judge
The order was signed by United States District Judge Vince Chhabria.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.