Garcia v. Sun-Hayward, LLC
- Jon Tigar
- 4:21-cv-08574
- U.S. District Court · Northern District of California
- 4
In Garcia v. Sun-Hayward, LLC, Judge Tigar declined supplemental jurisdiction and dismissed Garcia’s Unruh Act claim without prejudice.
Orlando Garcia’s California Unruh Act claim was dismissed without prejudice, while his ADA claim remained pending subject to a separate motion to dismiss and the filing requirements in the order. Sun-Hayward, LLC remained a defendant.
What happened
Orlando Garcia brought claims under the Americans with Disabilities Act and California’s Unruh Civil Rights Act against Sun-Hayward, LLC. The two claims arose from the same alleged facts, so the federal court initially had authority to consider both together.
The court decided that exceptional circumstances and concerns about fairness between federal and state courts justified not hearing the Unruh Act claim. The case was still at the pleading stage, and California courts should have the opportunity to apply California’s special rules for these claims.
Judge Jon S. Tigar declined supplemental jurisdiction over the Unruh Act claim and dismissed it without prejudice. Garcia had two weeks to state that he would proceed only with his federal disability claim or to voluntarily dismiss the case; a motion challenging the federal claim remained pending.
The detailed version
- Garcia v. Sun-Hayward, LLC · No. 4:21-cv-08574
- Jon Tigar
- Jan. 5, 2023
Background
Orlando Garcia asserted an Americans with Disabilities Act (ADA) claim and a California Unruh Civil Rights Act claim against Sun-Hayward, LLC. The court explained that the claims arose from a common set of facts and therefore were part of the same case or controversy for purposes of supplemental jurisdiction, which is a federal court’s authority to hear related state-law claims alongside federal claims.
The court was considering whether to continue exercising that authority over the Unruh Act claim after Garcia responded to an order asking why the court should not decline jurisdiction. The case had not progressed beyond the pleadings stage. A motion to dismiss the ADA claim for lack of subject-matter jurisdiction also remained pending, based on Defendants’ contention that they had remediated, or were remediating, the alleged access barriers.
Reason for Declining Jurisdiction
Under 28 U.S.C. § 1367(c)(4), a court may decline supplemental jurisdiction when exceptional circumstances exist and compelling reasons support doing so. Relying on Ninth Circuit decisions, the court found exceptional circumstances because California-law rules governing ADA-based Unruh Act cases create special pleading standards, procedural requirements, and filing requirements, including additional requirements for high-frequency litigants.
The court concluded that retaining the claim could interfere with California’s reforms and deprive California courts of their role in applying those rules. Because the case was at an early stage, the court found that fairness and respect for the state court system were compelling reasons to decline jurisdiction.
Ruling
The court declined to exercise supplemental jurisdiction over Garcia’s Unruh Act claim and dismissed that claim without prejudice. The order required Garcia, within two weeks, to file a statement that he intended to proceed solely on the ADA claim in federal court or to file a notice or stipulation of voluntary dismissal as appropriate under Federal Rule of Civil Procedure 41(a)(1).
The order stated that if Garcia failed to file a timely statement, the court would dismiss the ADA claim for failure to prosecute under Rule 41(b) and close the case. The order did not decide the pending motion to dismiss the ADA claim.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.