Sepulveda v. Guo

Background

Richard Sepulveda alleged that he uses a walker and encountered architectural barriers during four visits to defendants’ restaurant. The alleged barriers involved the sidewalk leading to the front entrance, dining seating, the path to the restroom, and the restroom’s interior. His complaint asserted claims under Title III of the Americans with Disabilities Act (ADA), the California Unruh Civil Rights Act, and other state laws.

Defendant Wei Zhong Guo filed the motion to dismiss, and the remaining defendants later joined it. Defendants asked the court to decline supplemental jurisdiction—the federal court’s authority to hear related state-law claims—and dismiss the state claims.

Court’s analysis

The court applied 28 U.S.C. § 1367. Although related state claims ordinarily may be heard with a federal claim, the statute allows a court to decline that authority in exceptional circumstances for compelling reasons. The court relied on the Ninth Circuit’s decision in Arroyo v. Rosas, which held that allowing ADA-based Unruh Act claims to proceed in federal court could undermine California’s reforms for “high-frequency litigants.” Those reforms require such litigants to plead additional facts and pay an additional filing fee.

The court found that Sepulveda’s case presented the exceptional circumstance described in Arroyo. The court noted that Sepulveda conceded he was a “high-frequency litigant” subject to California’s procedural standards and concluded that filing his ADA-based Unruh Act and related state claims in federal court had evaded the Unruh Act’s “critical limitations” on damages. Unlike the case discussed in Arroyo, this case was still in its early stages, so judicial efficiency, convenience, fairness, and respect for state courts favored declining supplemental jurisdiction.

The court rejected Sepulveda’s arguments that he was less litigious than other high-frequency litigants, had satisfied California’s heightened pleading requirements, and was not motivated by quick settlements. Relying on Ninth Circuit precedent, the court said that deciding those threshold questions in federal court would interfere with state courts’ role in enforcing California’s reforms.

Disposition

The court granted defendants’ motion to dismiss Sepulveda’s Unruh Act claim and other related state claims. The court dismissed those claims without prejudice to refiling in state court. It separately denied defendants’ requests for judicial notice because they were filed after the reply without complying with the applicable local rule. The order also set a telephonic case management conference and required the parties to submit a joint case management statement.