Woods v. Airbnb, Inc.

Background

Cindy Woods’s amended complaint alleges that her adult daughter, Monique Woods, booked an Airbnb rental in Croatia and died there on May 14, 2022, from carbon-monoxide poisoning caused by gases from an improperly installed gas boiler. Woods asserted seven causes of action against Airbnb, Inc., Airbnb Payments, Inc., and Vesna Salamunovic, who allegedly owns the property. The first cause of action was a wrongful-death claim brought by Woods in her personal capacity. The second cause of action was a negligence claim brought both personally and as a survival claim on behalf of the decedent. The third through seventh causes of action were also survival claims.

Earlier Arbitration Ruling

In an August 28, 2024 order, the court granted in part and denied in part Airbnb’s motion to compel arbitration. The court granted the motion as to the survival claims because of an arbitration agreement between the decedent and Airbnb, and stayed those claims pending arbitration. The court denied the motion as to the wrongful-death claims because it found that those claims were not covered by an arbitration agreement between Woods and Airbnb.

Motion to Stay the Wrongful-Death Claims

Airbnb then moved to stay the wrongful-death claims while the survival claims were arbitrated. An arbitration is a process in which an arbitrator, rather than the court, decides covered claims. A stay pauses court proceedings. Woods filed no response to the motion.

The court explained that it had discretion to stay non-arbitrable claims while related arbitrable claims proceeded. Such a stay was appropriate when the arbitrable claims predominated or when the outcome of the non-arbitrable claims depended on the arbitration. The court concluded that the wrongful-death claims depended on the arbitrator’s decision about the survival claims. Both types of claims depended on Airbnb’s liability, and an adverse decision on the survival claims could also defeat the wrongful-death claims.

The court also noted that the arbitration would address central issues relevant to the wrongful-death claims, including Airbnb’s duties to people who reserve lodging through its website and whether a breach of those duties proximately caused an injury. Proceeding with the court case at the same time as the arbitration could require parallel discovery and proceedings and waste judicial resources.

Disposition

The court granted Airbnb’s motion. The wrongful-death claims asserted by Woods against Airbnb were stayed pending completion of the arbitration of the survival claims. The order did not state that those claims were dismissed or decide their merits.