Vo v. Choi

When declining to exercise supplemental jurisdiction for a state-law claim under 28 U.S.C. § 1367(c)(4), a district court must: (1) sufficiently explain “why the circumstances of the case are exceptional” under § 1367(c)(4); and (2) show that “the balance of the Gibbs values provides compelling reasons for declining jurisdiction in such circumstances.” Arroyo v. Rosas, 19 F.4th 1202, 1210–11 (9th Cir. 2021).

Vo, an individual with a disability, visited Choi’s shopping plaza and later alleged she faced numerous barriers to access in violation of the Americans with Disabilities Act (ADA) and Unruh Act. She brought suit in federal district court on these claims. The district court declined to exercise supplemental jurisdiction over the Unruh Act claim, and Vo appealed the order. When declining to exercise supplemental jurisdiction for a state-law claim under 28 U.S.C. § 1367(c)(4), a district court must: (1) sufficiently explain “why the circumstances of the case are exceptional” under § 1367(c)(4); and (2) show that “the balance of the Gibbs values provides compelling reasons for declining jurisdiction in such circumstances.” Arroyo v. Rosas, 19 F.4th 1202, 1210–11 (9th Cir. 2021). The Court reasoned that the first prong was satisfied because allowing plaintiffs to evade California’s procedural requirements by bringing their claims in federal court would be unfair to defendants and “an affront to the comity between federal and state courts.” The second prong was also satisfied because the district court explicitly cited the Gibbs values and stated why they favored declining jurisdiction, and the decision was made before the district court ruled on the merits of the ADA claim. Affirmed.