Johnson v. Ruiz
- Susan Illston
- 3:22-cv-00802
- U.S. District Court · Northern District of California
- 3
In Johnson v. Ruiz, Judge Illston declined supplemental jurisdiction over Johnson’s state-law Unruh Act claim while his ADA claim remained pending.
Scott Johnson’s California Unruh Act claim was left for possible pursuit in state court; his ADA claim remained pending for a hearing on his motion for default judgment.
What happened
In Johnson v. Ruiz, Scott Johnson brought claims under the federal Americans with Disabilities Act and California’s Unruh Civil Rights Act. The court had not decided the merits of his ADA claim.
The court considered the case exceptional because Johnson had filed more than 2,500 construction-barrier cases in the Northern District of California since 2015. It concluded that allowing the state claim to proceed in federal court could let high-frequency litigants avoid California’s procedural requirements and that fairness and respect for state courts favored declining jurisdiction.
Judge Susan Illston declined supplemental jurisdiction over Johnson’s Unruh Act claim. Johnson may pursue that claim in state court, and the court scheduled a hearing on his motion for default judgment on the ADA claim.
The detailed version
- Johnson v. Ruiz · No. 3:22-cv-00802
- Susan Illston
- Oct. 11, 2022
Background
The court received Scott Johnson’s response to an order requiring him to explain why the court should retain supplemental jurisdiction over his California Unruh Act claim. Supplemental jurisdiction is a federal court’s authority to hear a related state-law claim alongside a federal claim. Johnson also asserted a claim under the Americans with Disabilities Act (ADA), but the court stated that it had not made any determination on the merits of that claim.
Why the Court Declined Jurisdiction
The court applied 28 U.S.C. § 1367(c)(4), which permits a federal court to decline supplemental jurisdiction in exceptional circumstances when the relevant considerations strongly support doing so. The court found this case exceptional because Johnson was a “high-frequency litigant” who had filed more than 2,500 construction-barrier cases in the Northern District of California since 2015, including at least 47 cases in the preceding two months.
The court relied on concerns that plaintiffs could use federal ADA claims to bring related Unruh Act monetary claims in federal court and avoid California’s procedural requirements for construction-barrier cases. It concluded that fairness and comity—respect for the roles of state and federal courts—weighed strongly in favor of declining jurisdiction. The court also stated that judicial-economy concerns were not implicated because it had not decided the ADA claim on the merits.
Disposition
The court declined supplemental jurisdiction over Johnson’s Unruh Act claim. It stated that Johnson was free to pursue that claim in state court. The court also stated that it would hold a hearing on Johnson’s motion for default judgment on the ADA claim on October 14, 2022. This order did not decide the merits of the ADA claim.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.