Johnson v. Jia He Corporation
- Joseph Spero
- 3:21-cv-04702
- U.S. District Court · Northern District of California
- 2
In Johnson v. Jia He Corporation, Judge Spero declined supplemental jurisdiction, dismissed both claims without prejudice, and denied fees.
Scott Johnson’s Unruh Act and Americans with Disabilities Act claims were dismissed without prejudice to refiling in state court; Jia He Corporation’s request for attorneys’ fees was denied.
What happened
In Johnson v. Jia He Corporation, Scott Johnson brought claims under California’s Unruh Act and the Americans with Disabilities Act. The court had ordered him to explain why it should continue hearing the Unruh Act claim.
Johnson agreed that nothing about his case changed the court’s earlier reasoning in a related decision. He also asked the court to dismiss his federal disability claim without prejudice so he could refile it in state court. Jia He Corporation opposed that request, seeking discovery about Johnson’s standing, dismissal with prejudice, and reimbursement of its attorneys’ fees.
Judge Spero declined to hear the Unruh Act claim and dismissed it without prejudice to refiling in state court. He granted Johnson’s request to dismiss the Americans with Disabilities Act claim without prejudice, denied Jia He’s request for attorneys’ fees, and closed the case.
The detailed version
- Johnson v. Jia He Corporation · No. 3:21-cv-04702
- Joseph Spero
- Aug. 9, 2022
Background
Scott Johnson’s complaint included a claim under California’s Unruh Civil Rights Act and a federal claim under the Americans with Disabilities Act. The court ordered Johnson to show why it should not decline to exercise supplemental jurisdiction—the authority to hear a state-law claim alongside a federal claim—for the reasons discussed in an earlier related proceeding and based on a Ninth Circuit decision. Johnson responded that nothing novel about his case would change the court’s prior reasoning.
Unruh Act claim
The court declined to exercise supplemental jurisdiction over Johnson’s Unruh Act claim. It dismissed that claim without prejudice to refiling in state court.
Americans with Disabilities Act claim and fees
Johnson also asked the court to dismiss his Americans with Disabilities Act claim without prejudice to refiling in state court. Jia He Corporation asked the court to treat that request as a motion under Federal Rule of Civil Procedure 41(a)(2). Jia He sought either denial of the motion and jurisdictional discovery about whether Johnson had standing to sue in federal court, or dismissal with prejudice and reimbursement of its attorneys’ fees.
The court found that Jia He had not shown that Johnson lacked standing or that the case was frivolous when filed. It also noted that Jia He had not previously challenged Johnson’s standing during the more than one year the case was pending and had answered the complaint without moving to dismiss. The court concluded that jurisdictional discovery would waste resources because Johnson no longer wished to pursue the claim in that forum.
The court construed Johnson’s request as a Rule 41(a)(2) motion, granted it, and dismissed the Americans with Disabilities Act claim without prejudice to refiling in state court. The court denied Jia He’s request for attorneys’ fees. It stated that the order did not prejudice any defense or argument Jia He might raise in state court. The Clerk was instructed to close the case.
Classification
This is a procedural order because the court declined supplemental jurisdiction over the state-law claim and granted a dismissal without prejudice of the federal claim without deciding the underlying claims’ merits.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.