Unreported / Non-Citable
Background
Latanya Williams sued Hassal, Inc. and other defendants in the Central District of California. As the court describes the complaint, it asserts a claim for injunctive relief based on an alleged violation of the Americans with Disabilities Act and a claim for damages under California's Unruh Civil Rights Act, Civil Code sections 51 through 53. Those are the plaintiff's allegations. The order does not decide whether any violation occurred.
Judge Percy Anderson observed that it appears the court has only supplemental jurisdiction over the Unruh Act claim, and over any other state-law claim the plaintiff may have pleaded, under 28 U.S.C. section 1367(a). The order relies on City of Chicago v. International College of Surgeons, which quotes Carnegie-Mellon University v. Cohill. Those cases say a federal court should weigh judicial economy, convenience, fairness, and comity in each case and at every stage of the litigation. The court framed the inquiry under 28 U.S.C. section 1367(c), the provision that governs whether a court may decline supplemental jurisdiction.
The Court’s Holding
This is a procedural order to show cause. It is not a ruling on the merits, and it does not finally decide whether the court will keep the state-law claims. The court ordered the plaintiff to show cause in writing why it should exercise supplemental jurisdiction over the Unruh Act claim and any other state-law claim asserted in the complaint. The written response is due by November 11, 2026.
The order adds two requirements. First, the plaintiff must identify the amount of statutory damages she seeks to recover. Second, the plaintiff and her counsel must support their responses with declarations signed under penalty of perjury. The declarations must supply all facts the court needs to decide whether each of them meets the definition of a high-frequency litigant under California Code of Civil Procedure section 425.55(b)(1) and (2).
The order warns that a failure to respond timely or adequately may, without further warning, lead to dismissal of the entire action without prejudice. It also warns that the court may instead decline supplemental jurisdiction over the Unruh Act and other state-law claims, if any, and dismiss those claims under section 1367(c). These are stated consequences of non-compliance, not rulings. Nothing has been dismissed, and no judgment has been entered.
Key Takeaways
- The court treats its jurisdiction over the Unruh Act claim as uncertain and says it appears to rest only on supplemental jurisdiction, not on an independent federal basis.
- The plaintiff must explain in writing, by November 11, 2026, why the court should exercise supplemental jurisdiction rather than decline it under section 1367(c).
- The response must state the amount of statutory damages sought, which gives the court concrete information about the state-law claim.
- The plaintiff and her counsel must each file sworn declarations with the facts needed to decide high-frequency litigant status under Code of Civil Procedure section 425.55(b)(1) and (2).
- The possible outcomes are dismissal of the whole action without prejudice or dismissal of only the state-law claims, and neither has happened yet. A dismissal without prejudice would not be a final adjudication of the merits.
Why It Matters
The order shows a federal district court using its discretion over supplemental jurisdiction at the start of an ADA and Unruh Act case. The court invokes the principle that the economy, convenience, fairness, and comity factors are weighed at every stage. It also asks for sworn information on damages and on litigation frequency before deciding whether the state-law claim stays in federal court.
Because the order is only a directive to respond, it sets no precedent on how the court will rule. It is a minute order that does not resolve the jurisdictional question, and it carries no precedential weight. What remains open is how the plaintiff responds, what the declarations show, and whether the court keeps or declines the Unruh Act claim. Litigants in similar cases can read it as a sign of what a court may require, but the outcome here will depend on the response and the court's later ruling.