Johnson v. Peppin Properties LLC

Background

Scott Johnson sued Peppin Properties LLC and Panda Dumpling Inc. He alleged violations of the federal Americans with Disabilities Act (ADA) and California’s Unruh Act. The property at issue became vacant, and the parties agreed that the vacancy made Johnson’s ADA claim moot.

Court’s Analysis

The court explained that a person suing under the ADA must have standing at every stage of the case. Standing requires an actual injury, a connection between the injury and the defendants’ conduct, and the possibility that a favorable court decision will remedy the injury. Johnson conceded that he no longer had standing to seek injunctive relief under the ADA because closing the property meant that the requested relief could no longer be provided through this action.

Because Johnson no longer had standing to seek ADA injunctive relief, the court dismissed his ADA claim. The court then addressed Johnson’s remaining Unruh Act claim. After dismissing the only federal claim—the only claim giving the court original jurisdiction—the court declined to exercise supplemental jurisdiction over the state-law claim. Supplemental jurisdiction is a federal court’s authority to hear related state-law claims in the same case. The court stated that, because it declined that jurisdiction, it lacked subject-matter jurisdiction over the case.

Disposition

The court dismissed the action without prejudice and ordered the clerk to close the file. Judge Jon S. Tigar signed the order on December 8, 2022.