There is no alternative. It's not as though they departed JFK with insufficient fuel, it's simply that there was likely not an ounce more to be carried.
In reality, if the aircraft could make it to FAT, it can easily make it to SFO. But, not without dipping into reserves and that is something no Captain, no dispatcher, and no carrier will do.
I don't know how you define "rare" or "common" but it's certainly not an every day occurence. It's certainly something carriers don't want as it is costly and delays not only passengers, but the aircraft and crew as well.