Garcia v. Romo
- Vince Chhabria
- 3:22-cv-01169
- U.S. District Court · Northern District of California
- 1
In Garcia v. Romo, Judge Chhabria declined supplemental jurisdiction over the Unruh Act claim and granted Garcia’s request to dismiss the ADA claim without prejudice.
Orlando Garcia’s ADA claim was dismissed without prejudice, and the court declined supplemental jurisdiction over his Unruh Act claim; the Clerk of Court was permitted to close the case.
What happened
In Garcia v. Romo, the court declined to keep hearing Orlando Garcia’s claim under California’s Unruh Civil Rights Act. The court said the case was still at an early stage, so keeping the claim would not promote efficiency, convenience, fairness, or respect for state courts.
The court also cited the circumstances described in earlier decisions involving frequent filers of Americans with Disabilities Act and Unruh Act claims. It concluded that those circumstances supported declining supplemental jurisdiction, which is a federal court’s authority to hear related state-law claims.
Judge Vince Chhabria granted Garcia’s request to dismiss the ADA claim without prejudice. The Clerk of Court was permitted to close the case.
The detailed version
- Garcia v. Romo · No. 3:22-cv-01169
- Vince Chhabria
- Aug. 19, 2022
Background
The opinion concerns an Americans with Disabilities Act claim and a claim under California’s Unruh Civil Rights Act. The court stated that the case was in its early stages.
Court’s Analysis
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 comity did not favor retaining jurisdiction.
The court also stated that the facts of the case involved “a frequent filer of ADA and Unruh Act claims seeking federal jurisdiction to circumvent California’s procedural barriers to such suits.” It concluded 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.
Disposition
The court granted the plaintiff’s request to dismiss the ADA claim without prejudice. The court stated that the Clerk of Court may close the case. The order does not state a separate disposition for the Unruh Act claim beyond declining supplemental jurisdiction over it.
Judge
The order was signed by Vince Chhabria, United States District Judge.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.