Johnson v. Tea Hub, LLC
- Joseph Spero
- 3:21-cv-04545
- U.S. District Court · Northern District of California
- 1
In Johnson v. Tea Hub, LLC, Judge Spero ordered Johnson to explain why the court should not decline supplemental jurisdiction over his state claim.
Scott Johnson must respond to the court’s order regarding continued federal jurisdiction over his California Unruh Civil Rights Act claim; Tea Hub, LLC is the defendant in the case.
What happened
In Johnson v. Tea Hub, LLC, Scott Johnson brought a federal claim under the Americans with Disabilities Act and a California Unruh Civil Rights Act claim.
The court said Ninth Circuit precedent recognizes exceptional circumstances that may justify declining supplemental jurisdiction over state disability-access claims brought by frequent plaintiffs. It also noted that it had previously applied that reasoning in similar cases where neither claim had been decided on the merits.
Judge Spero ordered Johnson to show cause by December 7, 2022, why the court should not decline supplemental jurisdiction over his Unruh Act claim. The order did not decide either claim on the merits or finally determine whether the court would decline jurisdiction.
The detailed version
- Johnson v. Tea Hub, LLC · No. 3:21-cv-04545
- Joseph Spero
- Nov. 30, 2022
Background
Scott Johnson brought a claim under the Americans with Disabilities Act (ADA) and a state-law claim under California’s Unruh Civil Rights Act. He asked the federal court to exercise supplemental jurisdiction, which allows a federal court to hear certain related state-law claims along with federal claims.
Court’s analysis
The court cited Ninth Circuit precedent holding that concerns about comity—respect for state courts and state legal procedures—arising from California’s procedural rules for disability-access cases brought by frequent plaintiffs may qualify as exceptional circumstances for declining supplemental jurisdiction. The court also referred to its prior decision in a similar case, where it declined supplemental jurisdiction over parallel ADA and Unruh Act claims when neither claim had yet been decided on the merits.
Order
The court ordered Johnson to show cause, by filing a response no later than December 7, 2022, why the court should not decline supplemental jurisdiction over his Unruh Act claim. This was an order to respond, not a final ruling declining jurisdiction. The opinion did not decide the merits of either claim.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.