Gomez v. Reynolds Creative Products, Inc.
- Jon Tigar
- 4:22-cv-00830
- U.S. District Court · Northern District of California
- 4
In Gomez v. Reynolds Creative Products, Inc., Judge Tigar declined supplemental jurisdiction and dismissed Gomez’s Unruh Act claim without prejudice.
Andres Gomez’s California Unruh Act claim was dismissed without prejudice; his ADA claim remained subject to his required filing within two weeks.
What happened
In Gomez v. Reynolds Creative Products, Inc., the court considered whether to keep Gomez’s California Unruh Act claim alongside his Americans with Disabilities Act claim.
The court said the claims involve the same underlying facts, but California rules for these cases created exceptional concerns about the state courts’ role and fairness. Because the case was still at the pleading stage, the court found compelling reasons not to keep the Unruh Act claim.
Judge Tigar declined supplemental jurisdiction and dismissed the Unruh Act claim without prejudice. Gomez had two weeks to state that he would proceed only on the ADA claim in federal court or file an appropriate voluntary dismissal; otherwise, the court said it would dismiss the ADA claim for failure to prosecute and close the case.
The detailed version
- Gomez v. Reynolds Creative Products, Inc. · No. 4:22-cv-00830
- Jon Tigar
- Jan. 5, 2023
Background
Andres Gomez asserted a claim under the Americans with Disabilities Act (ADA) and a claim under California’s Unruh Civil Rights Act. The court had original jurisdiction over the ADA claim and supplemental jurisdiction—authority to hear a related state-law claim—over the Unruh Act claim. After reviewing Gomez’s response to an order to show cause, the court decided whether to retain the state-law claim.
Court’s Analysis
The court concluded that the ADA and Unruh Act claims formed part of the same case or controversy because they arose from a common set of facts. But federal law permits a court to decline supplemental jurisdiction in specified circumstances, including when exceptional circumstances create compelling reasons to do so.
The court relied on Ninth Circuit decisions recognizing that several California rules create an unusual systemic impact on ADA-based Unruh Act cases. Those rules include special pleading and procedural requirements for plaintiffs generally, as well as additional requirements and higher filing fees for high-frequency litigants. The court said that retaining these claims in federal court could interfere with California’s reforms and deprive California courts of their role in applying those rules.
The court also found that fairness and respect for the state court system supported declining jurisdiction. The case had not progressed beyond the pleadings stage, so sending the Unruh Act claim to state court would allow that court to address the California-specific procedures early in the litigation. The court noted that the Northern District of California’s General Order 56, which governs ADA access cases, did not address the particular concerns behind California’s heightened pleading rules for high-frequency litigants.
Disposition
The court declined to exercise supplemental jurisdiction over Gomez’s Unruh Act claim and dismissed that claim without prejudice. The court ordered Gomez, within two weeks, to file a statement that he intended to proceed solely on the ADA claim in federal court or to file an appropriate notice or stipulation of voluntary dismissal. If he did not timely file the required statement or dismissal, the court said it would dismiss the ADA claim for failure to prosecute under Federal Rule of Civil Procedure 41(b) and close the case. Judge Jon S. Tigar signed the order.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.