Unreported / Non-Citable
Background
Rogelio Santibanez filed a complaint against Ready Wholesale Electric And Lighting, Inc. and other defendants asserting a claim for injunctive relief based on an alleged violation of the Americans with Disabilities Act. The complaint also seeks damages under California's Unruh Civil Rights Act. The court's order describes these allegations and claims but does not decide whether the ADA was violated or whether Santibanez is entitled to relief.
In civil minutes issued in chambers on November 4, 2026, the Central District of California stated that it appeared to possess only supplemental jurisdiction over the Unruh Act claim and any other state-law claim alleged in the complaint. The court identified 28 U.S.C. § 1367(a) as the relevant supplemental-jurisdiction provision. No attorneys were present for either side, and the order did not report an oral hearing or resolve any merits issue.
The court invoked the Supreme Court's guidance in City of Chicago v. International College of Surgeons, emphasizing that a federal court should weigh judicial economy, convenience, fairness, and comity at every stage of the litigation when deciding whether to exercise supplemental jurisdiction. This framework underlies the court's decision to require a written response rather than ruling immediately on the state-law claims.
The Court’s Holding
Judge Percy Anderson ordered Santibanez to show cause in writing why the court should exercise supplemental jurisdiction over the Unruh Act claim and any other state-law claim asserted in the complaint. The court explained that decisions about supplemental jurisdiction require consideration of judicial economy, convenience, fairness, and comity at every stage of litigation. It cited 28 U.S.C. § 1367(c) in directing the plaintiff to justify retention of the state-law claims.
The response must identify the amount of statutory damages Santibanez seeks. Both Santibanez and his counsel must support their responses with declarations signed under penalty of perjury that provide all facts necessary for the court to determine whether they meet California's definition of a "high-frequency litigant" under California Code of Civil Procedure sections 425.55(b)(1) and (2). The written response is due no later than November 18, 2026.
The court warned that a late or inadequate response could, without further warning, result in dismissal of the entire action without prejudice. Alternatively, the court could decline supplemental jurisdiction over the Unruh Act and other state-law claims and dismiss those claims under § 1367(c). These are potential consequences of noncompliance, not dismissals already ordered, and the ADA claim remains unresolved.
Key Takeaways
- The court has not dismissed the complaint or decided the merits of the ADA and Unruh Act allegations.
- Santibanez must file a written response by November 18, 2026, explaining why supplemental jurisdiction should be exercised over the state-law claims.
- The response must specify the statutory damages sought and include sworn declarations from both the plaintiff and his counsel addressing high-frequency-litigant status.
- Failure to respond timely or adequately may lead to dismissal of the entire action without prejudice or dismissal of the state-law claims after the court declines supplemental jurisdiction.
- The order requires facts sufficient to determine whether Santibanez or his counsel qualifies as a high-frequency litigant under California Code of Civil Procedure sections 425.55(b)(1) and (2).
Why It Matters
The order places the jurisdictional basis for the state-law claims at issue early in the case and requires information bearing on both supplemental jurisdiction and California's high-frequency-litigant provisions. It does not establish that Santibanez or his counsel meets that definition; instead, it requires sworn facts so the court can make that determination.
The immediate practical consequence is a compliance deadline with a substantial dismissal warning. The court expressly preserved the possibility of declining supplemental jurisdiction under § 1367(c), while leaving the underlying discrimination allegations and any entitlement to injunctive relief or damages undecided.