Arroyo v. Rosas, No. 19-55974 (9th Cir. 2021)
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Arroyo, who uses a wheelchair for mobility, sued the owner of a California liquor store under the Americans with Disabilities Act, 42 U.S.C. 12181, and California’s Unruh Civil Rights Act. The district court granted Arroyo summary judgment on his ADA claim. Any violation of the ADA is automatically a violation of the Unruh Act, CAL. CIV. CODE 51(f), but the district court concluded that “compelling reasons” existed under 28 U.S.C. 1367(c)(4) to decline supplemental jurisdiction and dismiss Arroyo’s Unruh Act claim. Recent changes in California law had made it more difficult to file Unruh Act claims in state court, resulting in a wholesale shifting of such cases to the federal courts.
The Ninth Circuit reversed and remanded. The extraordinary situation created by the unique confluence of California rules involved here, which has led to systemic changes in where such cases are filed, presents “exceptional circumstances” that authorize consideration, on a case-by-case basis, of whether the “‘principles of economy, convenience, fairness, and comity which underlie the pendent jurisdiction doctrine’” warrant declining supplemental jurisdiction. However, because the district court effectively completed its adjudication of this entire case—including the Unruh Act claim—before it considered the question of supplemental jurisdiction, the interests in judicial economy, convenience, comity, and fairness at that point all overwhelmingly favored retaining jurisdiction and entering the foreordained judgment on the Unruh Act claim.
Court Description: Supplemental Jurisdiction. The panel reversed the district court’s order granting summary judgment to plaintiff on his claim under Title III of the Americans with Disabilities Act but declining to exercise supplemental jurisdiction over his claim under California’s Unruh Civil Rights Act. The panel held that, because any violation of the ADA is automatically a violation of the Unruh Act, the district court’s summary judgment ruling effectively dictated the outcome of plaintiff’s Unruh Act claim as well. The panel held that the district court abused its discretion in nonetheless declining to exercise supplemental jurisdiction over the Unruh Act claim under 28 U.S.C. § 1367(c)(4), which permits a district court to decline to exercise supplemental jurisdiction over a claim if, “in exceptional circumstances, there are other compelling reasons for declining jurisdiction.” * The Honorable Bobby R. Baldock, United States Circuit Judge for the U.S. Court of Appeals for the Tenth Circuit, sitting by designation. ARROYO V. ROSAS 3 According to the district court, recent changes in California law had made it much more difficult to file Unruh Act claims in state court, leading to a wholesale shifting of such cases to the federal courts. The district court ruled that retaining jurisdiction over the Unruh Act claim would allow plaintiff to evade the California requirements, contrary to the interest in federal-state comity. The panel agreed with the district court that the extraordinary situation created by the unique confluence of California rules involved here, pairing a damages remedy with special procedural requirements aimed at limiting suits by high-frequency litigants, presented “exceptional circumstances” that authorized consideration, on a case-by- case basis, of whether the principles of judicial economy, convenience, comity, and fairness underlying the pendent jurisdiction doctrine provided “compelling reasons” that warranted declining supplemental jurisdiction. However, because the district court effectively completed its adjudication of this case before it considered the question of supplemental jurisdiction, the interests in judicial economy, convenience, comity, and fairness all overwhelmingly favored retaining jurisdiction and entering the foreordained judgment on the Unruh Act claim. The panel therefore reversed and remanded. 4 ARROYO V. ROSAS
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