How have courts dealt with disparate impact disability claims?

In Hunsaker v. Contra Costa County , the plaintiff brought disparate impact disability claims under both federal and state law, seeking a permanent injunction. 149 F.3d 1041, 1042 (9th Cir. 1998). The district court ordered the injunction on the federal claim. Id . This court reversed, holding that there was no violation of the federal law. Id. at 1044. Over the plaintiff's argument that we should, nonetheless, uphold the injunction under the alternative state law claim, we held, "[t]he district court did not rule on this claim, and we have nothing to review. We should allow the district court to consider this claim in the first instance or, in its discretion, decline to exercise supplemental jurisdiction." Id .