US Judge Lin Skeptical of Lyft Sexual Assault MDL Motion to Dismiss

• Lyft sought to dismiss negligence and product liability claims in a federal MDL consolidating 136 sexual assault lawsuits.
• Judge Rita Lin expressed skepticism about Lyft's argument that a 2017 California PUC decision preempts negligence claims related to background checks.
• Lyft argued its app is not a product for liability, citing state court rulings, but plaintiffs noted a federal judge allowed product liability claims in the Uber MDL.
• The MDL is part of a larger legal challenge against Lyft and Uber, with thousands of sexual assault cases pending across state and federal courts.
• Plaintiffs allege ride-hailing companies prioritize profit over safety, failing to properly screen drivers and downplaying risks.

Judge Lin expressed considerable skepticism regarding this preemption argument, articulating her doubts about the idea that a PUC decision not to adopt a regulation for network-transportation companies like Lyft would automatically relieve the company of its traditional civil liability obligations.

Lyft Inc. recently sought to curtail a significant portion of the claims within a federal multidistrict litigation (MDL) that consolidates approximately 136 individual lawsuits. These cases allege that riders were sexually assaulted by drivers they were connected with through the Lyft app. During a hearing in San Francisco, U.S. District Judge Rita Lin, who presides over the Lyft sexual assault MDL, heard arguments on the company's motion to dismiss certain claims but did not issue an immediate ruling.

Central to Lyft's argument regarding negligence claims was the assertion that a 2017 decision by the California Public Utilities Commission (PUC) bars these claims. The PUC had previously considered and rejected a requirement for ride-hailing companies to implement fingerprint-based background checks for drivers. Lyft contended that this regulatory decision effectively preempted any civil liability for negligence related to background checks.

However, Judge Lin expressed considerable skepticism regarding this preemption argument, articulating her doubts about the idea that a PUC decision not to adopt a regulation for network-transportation companies like Lyft would automatically relieve the company of its traditional civil liability obligations. Lyft's attorney, David Riskin, maintained that the PUC's decision, which followed a review of evidence and public comments, concluded that fingerprint checks would not demonstrably enhance passenger safety. Despite this, Judge Lin indicated that a jury finding Lyft negligent, based on the company's actual knowledge concerning rider safety, would not necessarily conflict with the PUC's regulatory authority. Plaintiffs' counsel countered that they should be permitted to present evidence to a jury that Lyft's failure to use biometric screening led to the acceptance of false IDs, thereby obscuring the true identities of some drivers.

Beyond the negligence arguments, Lyft also sought to dismiss product liability claims, arguing that its ride-hailing app does not constitute a "product" under California law. In support of this position, Lyft referenced prior decisions in consolidated sexual assault cases within California state courts, where judges had previously sided with both Uber and Lyft on this specific issue. These state court rulings have generally held that the apps are services, not products, for liability purposes.

Conversely, the plaintiffs highlighted a differing outcome in the federal Uber sexual assault MDL. In that separate but related litigation, the federal judge overseeing the Uber MDL allowed product liability claims to proceed. This decision was based on the reasoning that while Uber provides a service, it also maintains total control over its application, which the court viewed as a product. This divergence in judicial interpretation regarding the nature of ride-hailing apps presents a significant legal challenge for companies like Lyft and impacts the potential avenues for claims in these complex litigations.

The current Lyft multidistrict litigation is part of a much larger wave of legal actions against both Lyft and its competitor, Uber. These lawsuits, predominantly brought by women, contend that ride-hailing businesses have prioritized financial gains over passenger safety. Specifically, plaintiffs allege that the companies have failed to adequately screen drivers and have misleadingly downplayed the risks faced by single women in their marketing.

The scale of these allegations is substantial; approximately 2,000 sexual assault cases against Lyft are already pending in a consolidated California state court proceeding established six years ago. Similarly, Uber is defending thousands of cases consolidated before a federal judge in San Francisco, in addition to a separate consolidated state-court proceeding. The master complaint in the Lyft MDL starkly asserts that "For Lyft, sexual assault and harassment in its vehicles is the price of doing business," further alleging that Lyft avoids responsibility by blaming drivers or even passengers, rather than ensuring the safe ride it promised.

Lawyers advising ride-hailing companies or representing plaintiffs in similar cases should note the judicial skepticism regarding regulatory decisions preempting traditional civil liability for negligence. The differing outcomes on whether a ride-hailing app constitutes a 'product' for liability purposes across federal and state courts also highlight an evolving area of law that impacts defense strategies and potential avenues for claims.

Source: Reporting based on Court News coverage