LYFT MEETS STATUTORY REQUIREMENTS FOR INDEPENDENT CONTRACTOR STATUS – SUMMARY JUDGMENT GRANTED
Last week, the Dallas Court of Appeals reviewed a trial court’s summary judgment in favor of Lyft, Inc. and concluded that Lyft was not responsible for a passenger’s injuries sustained while riding in a car driven by a Lyft driver, as a matter of law. In Freyer v. Lyft, Inc. 0221 WL 5879188 (Tex.App. – Dallas December 13, 2021), Molly Freyer used Lyft’s smartphone app to secure a ride from DFW Airport. During transit, the driver became ill, lost consciousness and Freyer then attempted to get out of the slow-moving vehicle. Her body got pinned between the back door and a concrete barrier and her foot was dragged along the concrete barrier for over 150 feet before the car stopped. Freyer sustained permanent foot, ankle and leg injuries and part of her right foot and big toe were amputated.
Freyer filed suit against the driver and Lyft, alleging a variety of negligence-based claims (e.g. hiring, supervision, training). Freyer settled with the driver and Lyft filed a traditional and no evidence motion for summary judgment seeking summary judgment as a matter of law in part because the driver suffered an unforeseeable incapacity and, the Transportation Network Companies (TNC) statute mandates that drivers are independent contractors. In response, Freyer argued that Lyft failed to comply with the TNC statute as needed to qualify the driver as an independent contractor. And fact issues precluded summary judgment on the negligence-based claims. The trial court disagreed and granted summary judgment in favor of Lyft. This appeal followed.
In its opinion, The Dallas Court of Appeals provides an excellent review of TNC statute, legislative intent, compliance requirements, related implications, and related case law. The court concluded that Lyft complied with the TNC’s statutory requirements and thus triggered the independent contractor provision as a matter of law. The opinion also provides a good analysis of the negligence-based claims asserted in the TNC context but ultimately concluded that “regardless of whether the statute abrogates common law negligence claims, Freyer, under the facts of this case, failed to raise genuine issues of material fact defeating summary judgment.” Accordingly, the trial court’s summary judgment was affirmed.