Sepulveda v. Taqueria y Carniceria Martinez LLC
- Susan Illston
- 3:23-cv-01781
- U.S. District Court · Northern District of California
- 3
In Sepulveda v. Taqueria, Judge Illston dismissed the state claims without prejudice and denied default judgment without prejudice to renewal on the ADA claim.
Richard Sepulveda’s California state-law claims were dismissed without prejudice, while his ADA claim remained pending. The defendants did not appear, and the motion for default judgment was denied without prejudice to renewal as to the ADA claim.
What happened
In Sepulveda v. Taqueria y Carniceria Martinez LLC, Richard Sepulveda brought a disability-access lawsuit asserting claims under the Americans with Disabilities Act and three California laws. The defendants did not appear, and the Clerk entered default, but the court had not yet entered a default judgment.
The court agreed that it should not decide the related state-law claims because the case was still at an early stage and deciding them in federal court could allow the plaintiff to avoid California’s procedural requirements. The court also found that declining to hear those claims would better respect the relationship between federal and state courts.
Judge Susan Illston adopted the magistrate judge’s recommendation in full, dismissed the state-law claims without prejudice to refiling them in state court, and denied the motion for default judgment without prejudice to renewing it as to the remaining ADA claim. A renewed motion was due by February 2, 2024.
The detailed version
- Sepulveda v. Taqueria y Carniceria Martinez LLC · No. 3:23-cv-01781
- Susan Illston
- Jan. 5, 2024
Background
Richard Sepulveda sued Taqueria y Carniceria Martinez LLC, Jirong Zhang, Feng Xin Li, and Does 1 to 50. The complaint asserted four causes of action: alleged violations of the Americans with Disabilities Act of 1990; California Health and Safety Code § 19955 et seq.; California’s Disabled Persons Act; and California’s Unruh Act.
The defendants failed to appear. The Clerk entered default on June 8, 2023. Sepulveda then moved for default judgment. Magistrate Judge Lisa Cisneros ordered him to explain why the court should not decline to exercise supplemental jurisdiction—the federal court’s authority to hear related state-law claims. Judge Cisneros later recommended declining supplemental jurisdiction over the state claims, dismissing those claims without prejudice, and denying the default-judgment motion without prejudice to renewal on the remaining ADA claim. No party objected.
Court’s Analysis
Judge Illston adopted Judge Cisneros’s report and recommendation in full. The court applied the Ninth Circuit’s two-step framework for declining supplemental jurisdiction under 28 U.S.C. § 1367(c)(4): determining whether exceptional circumstances exist and whether the principles of economy, convenience, fairness, and respect for state courts provide compelling reasons not to hear the state claims.
The court concluded that exceptional circumstances existed because the lawsuit combined an ADA claim with an Unruh Act claim in a way that could avoid California’s procedural requirements for disability-access cases. The court also found compelling reasons to decline jurisdiction because the case had not progressed beyond the pleading stage and the defendants had not appeared. It concluded that allowing the plaintiff to bypass California’s limitations would be unfair and would undermine respect between federal and state courts.
Disposition
The court declined to exercise supplemental jurisdiction over the state-law claims under § 1367(c)(4) and dismissed those claims without prejudice to refiling in state court. It denied Sepulveda’s motion for default judgment without prejudice to renewal as to the remaining ADA claim. The court set February 2, 2024, as the deadline for any renewed motion for default judgment. The order did not decide the merits of the ADA claim.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.