The Court explained that the framework for evaluating a district court’s decision not to exercise supplemental jurisdiction pursuant to 28 U.S.C. § 1367(c)(4) in a joint ADA and Unruh Act suit was set out in Arroyo v. Rosas, 19 F.4th 1202 (9th Cir. 2021). That case instructed that the court must articulate why the circumstances of the case are exceptional, and whether the balance of the values set out in United Mine Workers of America v. Gibbs, 383 U.S. 715 (1966) provides compelling reasons for declining jurisdiction in such circumstances. Applying this framework here, the Court held that the district court did not abuse its discretion in declining supplemental jurisdiction.

Because Voda’s assertion of the district court’s jurisdiction was based solely on 28 U.S.C. § 1367, the Federal Circuit did not consider other rationales for judicial authority to apply foreign law.The Federal Circuit briefly discussed the four limits on the reach of § 1367(a) and concluded that the only § 1367(a) issue was whether Voda’s claims of foreign patent infringement are part of the same case or controversy under Article III. The Court then conducted a legal analysis of the requirements for a “common nucleus of operative fact” under the standard first set forth in United Mine Workers of America v. Gibbs, 383 U.S. 715, 725 (1966), as elucidated by the Federal Circuit’s case in Mars. However, because the district court’s order failed to articulate any findings regarding the Mars factors, and because the Federal Circuit held that the district court abused its discretion under § 1367(c), the Court deemed it “to be the more prudent course not to decide this ‘common nucleus of operative fact’ question in the first instance.”