Unreported / Non-Citable
Background
Dena Peterson sued Neat Coffee Co., LLC and other defendants in the Central District of California. As described in the order, the complaint asserts claims under the Americans with Disabilities Act, 42 U.S.C. § 12131 et seq.; California's Unruh Civil Rights Act, Cal. Civ. Code §§ 51-53; California's Disabled Persons Act, Cal. Civ. Code § 54 et seq.; and negligence. These are allegations in the complaint, and the order makes no findings about whether any of them is true. The court states that it possesses only supplemental jurisdiction over the state-law claims, citing 28 U.S.C. § 1367(a).
The order, issued in chambers as civil minutes on October 28, 2026, quotes City of Chicago v. International College of Surgeons, 522 U.S. 156, 173 (1997), for the point that a federal court deciding whether to exercise supplemental jurisdiction should weigh judicial economy, convenience, fairness, and comity in each case and at every stage of the litigation. The court also points to the Ninth Circuit's decisions in Arroyo v. Rosas, 19 F.4th 1202 (9th Cir. 2021), and Vo v. Choi, 49 F.4th 1167 (9th Cir. 2022), as relevant authority 'including but not limited to' those cases. The order does not summarize what those decisions held or identify which ground under 28 U.S.C. § 1367(c) the court has in mind.
The Court’s Holding
The court did not decide whether to keep or decline jurisdiction over the state-law claims. It ordered Plaintiff to show cause in writing, on or before November 4, 2026, why the court should exercise supplemental jurisdiction over the state-law claims asserted in the complaint. That is a directive to brief the question, not a ruling on it, and no claim has been dismissed.
The order warns that failure to adequately comply may result in dismissal of this action with prejudice and without further notice. For the court's authority to dismiss on its own motion for failure to prosecute, it cites Federal Rule of Civil Procedure 41(b); Link v. Wabash R.R., 370 U.S. 626, 629 (1962); Hells Canyon Preservation Council v. U.S. Forest Service, 403 F.3d 683, 689 (9th Cir. 2005); and Ash v. Cvetkov, 739 F.2d 493, 496 (9th Cir. 1984). The warning is conditional ('may result'), and the order makes no finding of noncompliance. The stated consequence reaches the whole action, even though the show-cause question concerns only the state-law claims.
Key Takeaways
- This is an in-chambers show-cause order, not a merits ruling or a final judgment. Nothing has been dismissed, and what happens next depends on Plaintiff's written response.
- Plaintiff must explain by November 4, 2026 why the court should exercise supplemental jurisdiction over the Unruh Act, Disabled Persons Act, and negligence claims.
- The order frames the inquiry around judicial economy, convenience, fairness, and comity and cites Arroyo and Vo, but it does not say how those cases apply here.
- The order warns that inadequate compliance may result in dismissal with prejudice under Rule 41(b), but it does not say the ADA claim is deficient or that any party has defaulted.
- The order is unreported and issued by a district court in chambers, so it carries no precedential weight and decides nothing about the underlying allegations.
Why It Matters
The order shows a district judge raising supplemental jurisdiction on his own initiative, at the outset of a case that pairs a federal ADA claim with California disability-access and negligence claims. Plaintiffs filing similar combined complaints in this court should be prepared to justify a federal forum for the state-law claims, using the comity-focused framework the order cites rather than assuming the federal claim carries the state claims along.
Much remains open. The court has not ruled on supplemental jurisdiction, has not said whether it would decline jurisdiction under 28 U.S.C. § 1367(c), and has not addressed the ADA claim or any defense. This order does not say what would follow if the court declined jurisdiction, and it is a non-precedential case-management order, so it offers only a snapshot of how the court approached the issue at this stage.