Garcia v. Sunseri

Background

Orlando Garcia sued Gary James Sunseri and other defendants for money damages and injunctive relief under the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act. On April 11, 2022, the parties entered a consent decree that resolved the requested injunctive relief but did not resolve money damages.

The court previously ordered Garcia to explain why it should not dismiss the ADA claim and decline supplemental jurisdiction over the Unruh Act claim. Supplemental jurisdiction is a federal court’s authority to decide related state-law claims alongside federal claims. Garcia later reported that he had no objection to the court declining supplemental jurisdiction over the Unruh Act claim.

Rulings

The court held that the ADA claim was subject to dismissal because the parties had already resolved the requested injunctive relief. Relying on cited Ninth Circuit and Northern District of California authority, the court stated that the only relief available to private plaintiffs under the ADA is an injunction. Because no other relief was available under the ADA, the court dismissed Garcia’s ADA claim without leave to amend.

Because the ADA claim was the only federal claim, the Unruh Act claim could continue in federal court only through supplemental jurisdiction. The court stated that, ordinarily, when all federal claims are eliminated before trial, considerations such as judicial economy, convenience, fairness, and respect for state courts favor declining supplemental jurisdiction. The court also noted Garcia’s lack of objection.

Disposition and Effect

The court dismissed the Unruh Act claim without leave to amend and without prejudice to filing it in state court. It ordered the clerk to close the file. The opinion does not decide the merits of the alleged ADA or Unruh Act violations.