Garcia v. Chicken 4 U, Inc.
- Yvonne Rogers
- 4:22-cv-00913
- U.S. District Court · Northern District of California
- 1
In Garcia v. Chicken 4 U, Judge Rogers dismissed Garcia’s moot ADA claim and ordered him to explain why the remaining state-law claim should stay in federal court.
Orlando Garcia’s ADA claim was dismissed as moot. His Unruh Act claim remained subject to possible dismissal, and the order required him to respond within seven days; Chicken 4 U, Inc. remained the defendant.
What happened
In Garcia v. Chicken 4 U, Inc., Orlando Garcia told the court that his request for an order requiring compliance with the Americans with Disabilities Act had become moot. Because that relief was the only remedy available under the ADA, the court dismissed his entire ADA claim.
The only remaining claim was under California’s Unruh Civil Rights Act. The court said federal courts generally decline to keep such claims after a related ADA claim is dismissed, and noted that Garcia was described as a “high-frequency” litigant. The court therefore questioned whether it should continue exercising authority over the state-law claim.
Judge Yvonne Gonzalez Rogers ordered Garcia to explain in writing within seven days why keeping the Unruh Act claim in federal court would serve judicial efficiency, convenience, fairness, and respect for state courts. The order states that failing to respond on time will result in dismissal of that claim and, as a result, the entire action.
The detailed version
- Garcia v. Chicken 4 U, Inc. · No. 4:22-cv-00913
- Yvonne Rogers
- Sept. 14, 2022
Background
Orlando Garcia brought claims under the Americans with Disabilities Act and California’s Unruh Civil Rights Act against Chicken 4 U, Inc. The opinion states that Garcia filed a notice explaining that his claim for injunctive relief under the ADA had become moot. Injunctive relief is a court order requiring or prohibiting conduct. The court stated that this was the only remedy available under the ADA, so Garcia’s entire ADA claim was moot and was dismissed.
Remaining Claim and Supplemental Jurisdiction
After the ADA claim was dismissed, the only remaining claim was Garcia’s claim under the Unruh Act. Supplemental jurisdiction is a federal court’s authority to hear certain related state-law claims along with federal claims. The court stated that courts decline to exercise supplemental jurisdiction over Unruh Act claims after a parallel ADA claim has been dismissed. It also stated that Garcia’s status as a “high-frequency” litigant asserting an Unruh Act claim in federal court alongside an ADA claim was an exceptional circumstance supporting dismissal of the Unruh Act claim.
Order
The court did not yet dismiss the Unruh Act claim in this order. Instead, it ordered Garcia to respond in writing within seven days and explain how keeping the claim in federal court would further judicial economy, convenience, fairness, and comity, meaning respect for the roles of state and federal courts. The order states that failure to respond on time will result in dismissal of the Unruh Act claim and, by extension, the action. The court had already dismissed the ADA claim as moot.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.