Under 28 USC 1367(c)(4), the district court may decline jurisdiction of state law claims  if in extraordinary circumstances there are compelling circumstances for declining jurisdiction.  This decision affirms the district court’s ruling that there were extraordinary circumstances in this ADA, physical barriers case, because California’s Legislature had amended Civ. Code 52(a) and 55.56 to discourage repeat litigation by a small number of law firms and plaintiffs that were using the Unruh Act’s anti-disability discrimination provisions to shake down small businesses.  By filing in federal, rather than state, court, the plaintiffs in these cases managed to circumvent the protections the Legislature enacted–and as a result virtually all disability discrimination cases were filed in federal court, overloading their dockets.  However, the district court still abused its discretion in declining supplemental jurisdiction because it had already granted plaintiff summary judgment on the federal ADA claim, and California law provides that any ADA violation is automatically a violation of the Unruh Act.  Having, in effect, already adjudicated the state claim, it thwarted judicial efficiency and other policies to decline supplemental jurisdiction over that claim.