Johnson v. BW RRI II LLC

Background

Scott Johnson filed an Americans with Disabilities Act (ADA) claim seeking injunctive relief against BW RRI II LLC. On October 3, 2022, Johnson notified the court that the defendant had represented that the business involved in the case had closed and was being sold. Johnson stated that this indicated his request for injunctive relief was moot and that he had no objection to dismissal of the ADA claim. He also stated that, if the court dismissed his only federal claim, he had no objection to the court declining supplemental jurisdiction over his state-law claim so that he could refile it in state court.

Court’s Analysis

The court explained that, under the ADA, plaintiffs may seek injunctive relief and attorney’s fees. Because Johnson’s request for injunctive relief was moot, he no longer had standing—the legal requirement that a plaintiff have a live dispute that a court can resolve. The court therefore no longer had subject-matter jurisdiction over the ADA claim.

The court also addressed Johnson’s state-law Unruh Act claim. It explained that federal courts may decline supplemental jurisdiction over state-law claims when all claims within the court’s original jurisdiction have been dismissed. The court stated that, in the usual case where federal claims are eliminated before trial, the relevant factors favor declining jurisdiction over the remaining state-law claims.

Disposition

The court DISMISSED the ADA claim WITH PREJUDICE. It DISMISSED the Unruh Act claim WITHOUT PREJUDICE to refiling in state court. Judge Thomas S. Hixson ordered the case dismissed.