Gastelum v. TJX Companies

Background

Fernando Gastelum, who was proceeding without a lawyer, asserted claims under the Americans with Disabilities Act of 1990 and California’s Unruh Civil Rights Act. He challenged accessibility barriers that he said he encountered at stores allegedly owned or operated by The TJX Companies, Inc. (TJX).

TJX had argued that Gastelum lacked the required constitutional basis, called Article III standing, to pursue his ADA claim. TJX also argued that the court should dismiss the Unruh Act claim or decline to continue hearing it as a related state-law claim. On January 25, 2023, the court denied TJX’s motion to dismiss the ADA claim concerning a HomeGoods store in Gilroy, California. In the same order, the court required Gastelum to explain why it should not decline to hear the Unruh Act claim. Gastelum responded, but TJX did not submit a further response.

Supplemental jurisdiction analysis

A federal court that has authority over a federal claim may also hear a related state-law claim. But federal law permits the court to decline that authority in exceptional circumstances when compelling reasons exist. Courts weigh judicial economy, convenience, fairness, and respect for state courts and state policy, which the opinion refers to as the Gibbs factors.

The court found that exceptional circumstances existed here. Gastelum did not dispute that, if he pursued his Unruh Act claim in state court, California’s heightened procedural requirements for certain accessibility plaintiffs would apply. The court relied on Ninth Circuit precedent explaining that allowing such claims to proceed in federal court could avoid California’s restrictions and interfere with the state’s policy choices concerning damages and accessibility litigation.

Gastelum argued that judicial economy, fairness, and convenience favored keeping the claim in federal court. He said that refiling in state court would require another filing fee and that he found California’s state-court filing systems complex and less efficient. The court acknowledged that convenience and judicial economy may sometimes favor federal jurisdiction, but gave those considerations less weight because the case was still in its early stages. It concluded that the strong concerns about respecting California’s regulatory scheme outweighed Gastelum’s concerns.

The court also rejected Gastelum’s argument that California’s heightened requirements were expressly displaced by an ADA regulation. It found that the argument was not sufficiently developed or supported by authority that reached that conclusion.

Disposition

The court declined to exercise supplemental jurisdiction over the Unruh Act claim and dismissed that claim without prejudice to filing it in state court. The order did not dismiss the ADA claim addressed in the court’s earlier January 25 order and did not decide the merits of the Unruh Act claim.