Johnson v. Goodwill Of Silicon Valley
- Susan Van Keulen
- 5:21-cv-08410
- U.S. District Court · Northern District of California
- 2
In Johnson v. Goodwill Of Silicon Valley, Judge Van Keulen dismissed the Unruh Act claim without prejudice after the ADA claim became moot.
Scott Johnson’s California Unruh Civil Rights Act claim was dismissed without prejudice; the opinion did not decide whether that claim had merit.
What happened
Johnson v. Goodwill Of Silicon Valley involved Scott Johnson’s claims under the Americans with Disabilities Act and California’s Unruh Civil Rights Act. Johnson said the court had authority to hear the federal claim and the related state claim.
Johnson later reported that Goodwill had provided evidence that it fixed all alleged access barriers, suggesting that his request for an order requiring accessibility improvements was no longer a live dispute. Goodwill asked the court to dismiss the remaining Unruh Act claim, while Johnson asked the court to continue hearing it.
The court declined to continue hearing the state-law claim because the ADA claim was moot and considerations of fairness and respect for state courts favored leaving the Unruh Act claim to a state court. Judge Susan Van Keulen dismissed that claim without prejudice and directed the Clerk to close the case.
The detailed version
- Johnson v. Goodwill Of Silicon Valley · No. 5:21-cv-08410
- Susan Van Keulen
- Aug. 3, 2022
Background
Scott Johnson’s complaint asserted two claims against Goodwill Of Silicon Valley: one under the Americans with Disabilities Act of 1990 (ADA) and one under California’s Unruh Civil Rights Act. Johnson alleged that the court had federal-question jurisdiction over the ADA claim and supplemental jurisdiction—authority to hear a related state-law claim—over the Unruh Act claim.
Johnson later filed a notice stating that Goodwill had provided sufficient evidence that it had remedied all alleged access barriers at the business involved in the lawsuit. Johnson said this suggested that his request for injunctive relief under the ADA was moot, meaning that the requested court order no longer presented a live dispute.
Parties’ Positions
The parties filed a joint status report about how to resolve the remaining issues. Goodwill asked the court to dismiss the remaining Unruh Act claim on its own motion or, alternatively, to set a deadline for Goodwill to file a dismissal motion. Johnson argued that the court should continue exercising supplemental jurisdiction over the Unruh Act claim.
Court’s Analysis
The court determined that Johnson had indicated that his only federal-law claim was moot, leaving only the Unruh Act claim. Because that claim was before the federal court only through supplemental jurisdiction, the court considered whether to continue hearing it.
The court relied on the Ninth Circuit’s discussion of strong concerns about having federal courts hear Unruh Act claims and on decisions from the Northern District of California declining supplemental jurisdiction over such claims. The court concluded that continuing to hear the claim would not further economy, convenience, fairness, or respect for state courts, particularly because the ADA claim was moot.
Disposition
The court declined to exercise supplemental jurisdiction over the Unruh Act claim and DISMISSED WITHOUT PREJUDICE that claim. The court directed the Clerk of Court to close the file. Dismissal without prejudice does not bar refiling the claim, but the opinion did not decide the underlying merits of the Unruh Act claim.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.