Unreported / Non-Citable
Background
Yeong Lee filed this action on October 26, 2026, in the U.S. District Court for the Central District of California against San Antonio Bakery, Inc., Estela Flores Maciel as trustee of the Estela Flores Maciel Living Trust, and Doe defendants. The complaint asserted five claims: injunctive relief under the Americans with Disabilities Act; damages under California's Unruh Civil Rights Act; damages under California's Disabled Persons Act; damages and injunctive relief under California Health and Safety Code section 19955 and related provisions; and negligence. Lee maintained that the court had pendent jurisdiction over the state-law claims.
Four days after the filing, District Judge Monica Ramirez Almadani issued an in-chambers order to show cause concerning supplemental jurisdiction. The order did not dismiss any claim or decide the merits of the alleged accessibility violations. Instead, it addressed whether the federal court should retain the state-law claims accompanying the ADA request for prospective injunctive relief. The court required a written response within 14 days and warned that an untimely or inadequate response could result in its declining supplemental jurisdiction without further warning.
The Court’s Holding
The court explained that the power to exercise supplemental jurisdiction does not require its exercise in every case. It described supplemental jurisdiction as a doctrine of discretion rather than the plaintiff's choice and identified the statutory grounds for declining jurisdiction under 28 U.S.C. § 1367(c). Those grounds include novel or complex state-law issues, state claims that substantially predominate, dismissal of all claims within original jurisdiction, and exceptional circumstances supplying other compelling reasons. The decision requires weighing judicial economy, convenience, fairness, and comity at every litigation stage.
The order then focused on the interaction between the ADA and the Unruh Act. A private ADA litigant may obtain prospective injunctive relief, while California's Unruh Act relies on the ADA's substantive rules but expands available private remedies. Drawing on Arroyo v. Rosas, the court described California's concern that some ADA-Unruh litigation uses boilerplate complaints against small businesses to pursue quick settlements rather than accessibility corrections. California responded with verified, fact-specific pleading requirements for construction-related accessibility claims, additional disclosures and a special filing fee for high-frequency litigants.
The court noted that California district courts have declined supplemental jurisdiction over construction-related Unruh Act claims and related state claims brought by high-frequency litigants when federal litigation would circumvent state restrictions. It therefore ordered Lee to show cause why supplemental jurisdiction should be exercised here. Lee must identify the statutory damages sought. Lee and counsel must also submit declarations under penalty of perjury supplying facts needed to determine whether either meets California's high-frequency-litigant definition, including specified numbers of construction-related accessibility claims during the preceding 12 months. The court did not find that Lee or counsel actually met that definition.
Key Takeaways
- The order requires justification for retaining the state-law claims but does not dismiss them or resolve the underlying accessibility allegations.
- Lee must state the amount of statutory damages sought in the response to the order to show cause.
- Both Lee and Lee's counsel must provide declarations under penalty of perjury addressing the facts relevant to California's high-frequency-litigant definition.
- The required litigation-history disclosures include the plaintiff's construction-related accessibility filings and counsel's representation of high-frequency-litigant plaintiffs during the preceding 12 months.
- Failure to respond timely or adequately may lead the court to decline supplemental jurisdiction over the Unruh Act and related state-law claims without further warning.
Why It Matters
The order illustrates how federal courts may examine federal-state comity before exercising supplemental jurisdiction over damages claims paired with ADA accessibility litigation. Its immediate practical effect is to place the burden on the plaintiff and counsel to provide concrete damages and litigation-history information, while leaving the jurisdictional decision and the merits unresolved pending the required response.