Unreported / Non-Citable
Background
Meriah Gardea filed a complaint in the U.S. District Court for the Central District of California against Juice N Bowls WC 1 LLC and other defendants, docketed as No. 2:26-cv-12067-MWC-DSR. The complaint seeks damages and injunctive relief based on alleged violations of the Americans with Disabilities Act, California's Unruh Civil Rights Act, the California Disabled Persons Act, and a negligence theory. See Dkt. # 1.
On October 16, 2026, the Honorable Michelle Williams Court, United States District Judge, issued an in-chambers order to show cause concerning supplemental jurisdiction, filed as Document 10. The order did not decide whether the defendants violated any disability-access law, and it did not dismiss any claim. Instead, it required Gardea to explain in writing why the court should not decline to exercise supplemental jurisdiction over the Unruh Act claim and any related state-law claims.
The court anchored its inquiry in 28 U.S.C. § 1367(c)(4) and the Ninth Circuit's decision in Arroyo v. Rosas, 19 F.4th 1202 (9th Cir. 2021). That framework governs a district court's discretion to decline supplemental jurisdiction over state-law claims in exceptional circumstances. Because the complaint pleads both a federal ADA claim and state-law claims, the court's supplemental-jurisdiction decision will determine whether the Unruh Act, Disabled Persons Act, and negligence claims remain in federal court. The order invoked that framework not to resolve the jurisdictional question immediately, but to require a specific written response by a fixed deadline.
The Court’s Holding
The court ordered Gardea to show cause in writing no later than Friday, October 23, 2026, why the court should not decline to exercise supplemental jurisdiction over the Unruh Act and any related state-law claims. The order cites 28 U.S.C. § 1367(c)(4) alongside Arroyo v. Rosas, and it frames the question as one the plaintiff must persuade the court to answer in her favor. The response must also identify the amount of statutory damages Gardea seeks to recover, giving the court a concrete figure for evaluating the state-law claims.
Gardea and her counsel must support their responses with declarations signed under penalty of perjury. Those declarations must provide all facts necessary for the court to determine whether they satisfy the definition of a "high-frequency litigant" under California Code of Civil Procedure §§ 425.55(b)(1) and (2). The order therefore requires verified information from both the plaintiff and her counsel, rather than limiting the inquiry to the allegations in the complaint.
The court expressly warned that failure to respond as ordered will result in the court declining to exercise supplemental jurisdiction over the Unruh Act and related state-law claims and dismissing those claims without prejudice pursuant to 28 U.S.C. § 1367(c). That is a stated consequence of noncompliance, not a dismissal already imposed by this order. The order does not resolve the federal ADA claim or the merits of any underlying accessibility allegation.
Key Takeaways
- Gardea must file a written response by Friday, October 23, 2026, explaining why the court should retain supplemental jurisdiction over her state-law claims.
- The response must identify the amount of statutory damages she seeks to recover.
- Both Gardea and her counsel must provide declarations signed under penalty of perjury containing the facts relevant to the statutory high-frequency-litigant definition.
- Failure to comply will lead to dismissal of the Unruh Act and related state-law claims without prejudice, according to the order's express warning.
- The order concerns jurisdiction and required disclosures; it does not decide whether the defendants violated the ADA or California disability-access laws.
Why It Matters
The order places the immediate burden on the plaintiff and her counsel to provide concrete jurisdictional and litigation-history information. By requiring declarations addressing California's high-frequency-litigant provisions and a statement of statutory damages, the court set out the specific materials it will consider in deciding whether to retain the state-law claims alongside the federal ADA claim. This sequencing treats the high-frequency-litigant inquiry as part of the jurisdictional calculus under § 1367(c), not as a separate sanction.
The without-prejudice warning matters because the threatened disposition concerns supplemental jurisdiction rather than an adjudication of the merits. The order leaves the jurisdictional determination for after the ordered responses, while expressly preserving the possibility that the state-law claims will be dismissed without prejudice if Gardea does not comply. Any such dismissal would therefore be procedural, not a ruling on the accessibility allegations themselves.