Suing Lyft for the Negligence of its Driver
What happens when a Lyft driver causes a car crash, injures someone else, but wasn’t driving for Lyft at the time of the collision? In other words, when a driver is using a car that was furnished in-part by Lyft, but that driver was not actively driving for Lyft at the time of the crash, can the ride-sharing company be held liable for that driver’s negligence?
That was the question the California Court of Appeal decided last week in Marez v. Lyft, Inc.
Jonathan Gaurano rented a car to use as a Lyft driver. Lyft helped furnish the car through a partnership with Hertz Rental car. Mr. Gaurano also occasionally used the car for personal use. On the day of the collision with Ms. Marez, Mr. Gaurano was driving the car home from working at a convention. Lyft did not employ him at the convention, and Mr. Gaurano was not transporting passengers for Lyft nor signed into the Lyft app when he caused a collision with Ms. Marez’s vehicle.
Ms. Marez sued Mr. Guarano and Lyft. She argued that Lyft was responsible for Mr. Gaurano’s negligence under the legal theory of “Respondeat Superior”, which is the justification used to hold companies accountable for injuries caused by their employees while they are on the clock.
Respondeat Superior is a complicated legal theory that is highly fact-specific. In this case, the Court compared this case with precedent and found that Mr. Gaurano was not actively employed by Lyft at the time of the collision. In the Court’s own words:
“The undisputed facts compel the conclusion, as a matter of law, that Gaurano had substantially deviated from any duties he performed for Lyft at the time of the accident. Gaurano had not worked for Lyft on the day of the accident and had no intention of doing so. In the morning, Gaurano parked his vehicle at a location where he knew he would not receive a ticket for the day. He then travelled away from his vehicle and spent the day working for another employer. Lyft did not dictate how Gaurano should commute to this alternative job. It did not require Gaurano drive the rental vehicle or otherwise control his movements on the day in question. Nor was Gaurano’s commute home from the gaming conference related to his driving for Lyft. Gaurano testified his sole intent at the time of the accident was to go home to eat and sleep. Based on these undisputed facts, we conclude Gaurano was engaged in a purely personal activity at the time of the accident.”
The facts of this case strongly suggested that Gaurano was not on the clock for Lyft at the time of the collision, and the Court agreed. Why, then, would Ms. Marez seek to hold Lyft liable? It most likely has to do with insurance coverage. Lyft has higher insurance coverage when its drivers are actively using the App. But since Gaurano wasn’t on the clock at the time of the collision, it’s possible his personal policy did not adequately cover the losses and injuries he caused.
My office has experience with Uber and Lyft cases. They can be complicated, so if you or someone you know was involved in a Los Angeles Uber or Lyft crash, the Rabbi Lawyer is ready to assist, 24/6.
