Rafael Arroyo, Jr. v. Carmen Rosas

19 F.4th 1202 · Court of Appeals for the Ninth Circuit · 2021

Facts

Rafael Arroyo, Jr., a paraplegic, sued Carmen Rosas, owner of Gardena Main Plaza Liquor, alleging ADA and California Unruh Civil Rights Act violations due to architectural barriers. The district court granted summary judgment to Arroyo on his ADA claim, finding the barriers existed and were readily removable. However, the court declined to exercise supplemental jurisdiction over the Unruh Act claim, citing exceptional circumstances related to California's procedural changes for such claims and federal-state comity.

Issue

Did the district court abuse its discretion under 28 U.S.C. § 1367(c)(4) by declining supplemental jurisdiction over the Unruh Civil Rights Act claim, given that it had already granted summary judgment on the related ADA claim?

Holding

Yes, the Ninth Circuit reversed the district court's decision, holding that it abused its discretion. While the systemic shift of Unruh Act cases to federal court presented exceptional circumstances, the 'Gibbs values' (judicial economy, convenience, fairness, and comity) overwhelmingly favored retaining jurisdiction because the Unruh Act claim's outcome was effectively dictated by the ADA summary judgment.

Rule

A district court may decline supplemental jurisdiction under 28 U.S.C. § 1367(c)(4) in 'exceptional circumstances' for 'compelling reasons,' which requires a two-part inquiry: first, articulating why the circumstances are exceptional, and second, considering whether the 'principles of economy, convenience, fairness, and comity' (Gibbs values) warrant declining jurisdiction. However, if the federal court has effectively decided the state law claim, these values strongly favor retaining jurisdiction.

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Case brief last reviewed 2026-01-16. Prepared by CaseReader from the published opinion.