Johnson v. 1800 RC Partners, LLC
- Vince Chhabria
- 3:22-cv-01106
- U.S. District Court · Northern District of California
- 1
In Johnson v. 1800 RC Partners, LLC, Judge Chhabria dismissed the Unruh Act claim by declining supplemental jurisdiction and required the defendant to choose discovery or a hearing.
Scott Johnson’s Unruh Act claim was dismissed from the federal case. The defendant must choose between three months of jurisdictional discovery and proceeding directly to an evidentiary hearing; the order does not state the disposition of any other claims.
What happened
In Johnson v. 1800 RC Partners, LLC, Scott Johnson sued 1800 RC Partners, LLC, and others. The opinion addresses Johnson’s claim under California’s Unruh Civil Rights Act and refers to related claims under the Americans with Disabilities Act.
The court declined to keep the Unruh Act claim in federal court under supplemental jurisdiction, which can allow a federal court to hear a related state-law claim. The court said the case was at an early stage and that the relevant fairness and efficiency considerations did not favor keeping the claim. It also found exceptional circumstances because the court described the case as involving a frequent filer of Americans with Disabilities Act and Unruh Act claims seeking federal jurisdiction to avoid California procedural requirements.
The court dismissed the Unruh Act claim. It also ordered the defendant, within 14 days, to say whether it wanted three months of jurisdictional discovery about Johnson’s intent to return and whether he had personally visited the establishment, or instead wanted to proceed directly to an evidentiary hearing. Judge Vince Chhabria issued the order.
The detailed version
- Johnson v. 1800 RC Partners, LLC · No. 3:22-cv-01106
- Vince Chhabria
- June 21, 2022
Background
Scott Johnson brought claims against 1800 RC Partners, LLC, and others, including a claim under California’s Unruh Civil Rights Act. The order refers to related claims under the Americans with Disabilities Act. The opinion does not describe the pleadings or the specific conduct underlying the claims.
Jurisdictional ruling
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. The court relied on the early stage of the case and concluded that judicial economy, convenience, fairness to the litigants, and respect for state courts did not favor retaining the claim.
The court also stated that the case presented exceptional circumstances under 28 U.S.C. § 1367(c)(4). In doing so, it characterized the facts as involving a frequent filer of Americans with Disabilities Act and Unruh Act claims who sought federal jurisdiction to circumvent California’s procedural barriers to those suits.
Additional procedure and disposition
The order dismissed the Unruh Act claim. It directed the defendant to notify the court within 14 days whether it wanted a three-month period of jurisdictional discovery or preferred to proceed directly to an evidentiary hearing. If the defendant chose discovery, the permitted subjects would include Johnson’s intent to return and whether Johnson had personally visited the defendant’s establishment. The opinion does not state the disposition of any other claim.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.