Villegas v. Hesperian Boulevard, LLC

Background

Luis Villegas brought claims under the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act against Hesperian Boulevard, LLC, and other defendants. The order refers to the requesting party as “the plaintiffs,” although the caption identifies Luis Villegas as the plaintiff.

Court’s Analysis

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 a federal claim. The court relied on 28 U.S.C. § 1367(c)(4) and stated that the case was in its early stages, so judicial economy, convenience, fairness to the litigants, and comity did not favor keeping the state-law claim in federal court. The court also stated that the facts presented the type of exceptional circumstances supporting a decision not to exercise supplemental jurisdiction, describing the case as involving a frequent filer of ADA and Unruh Act claims seeking federal jurisdiction to avoid California procedural barriers.

Disposition

The court granted the request to dismiss the ADA claim without prejudice. It declined supplemental jurisdiction over the Unruh Act claim. The clerk was permitted to close the case, and the order was signed by Judge Vince Chhabria.