Taylor v. Uber Technologies Inc

Background

Uber Technologies Inc. and Rasier LLC asked the court to compel Adam Taylor to arbitrate his claims against them. The court had previously granted that motion, then vacated its order on reconsideration and allowed targeted discovery about whether Taylor had agreed to arbitration. After that discovery was completed, the court reconsidered the motion.

Taylor said he never agreed to arbitrate. It was undisputed that he created an account in Uber’s Driver App and used the app on January 5, 2024. During the registration process, he had to click “Yes, I agree” twice below a list of agreements, including the Rasier Platform Access Agreement, which contained an arbitration provision.

Evidence of Agreement

Uber presented an electronic business record showing that Taylor clicked “Yes, I agree” twice at 9:36:39 a.m. Central Standard Time on January 5, 2024. The record identified Taylor’s Driver ID, and the opinion states that the parties did not dispute that the ID belonged to Taylor or that he was using the app at that time. The court treated the electronic acceptance as an electronic signature and evidence of assent to the agreement.

Taylor relied primarily on screenshots from the Driver App and his testimony that he never agreed to arbitrate. The court organized the screenshots into three pairs. For the first pair, forensic analysis showed that Taylor took the underlying screenshot at 9:36:05 a.m., 34 seconds before Uber recorded his acceptance. For the second pair, the underlying screenshot was taken at 9:36:11 a.m., 28 seconds before the recorded acceptance. The court found that both screenshots were consistent with Taylor accepting the agreement shortly afterward.

The third screenshot was taken at 9:42 a.m. and showed that Taylor had not completed the driver-activation process. The court found that this did not show that he had not accepted the arbitration agreement because Uber presented evidence that Taylor still needed to upload a valid driver’s license, proof of insurance and a profile picture. The court concluded that none of the screenshots created a genuine dispute about assent.

The court also rejected Taylor’s challenge to the accuracy and authenticity of Uber’s electronic record. Uber presented evidence that it had found no relevant system errors, used procedures intended to ensure accurate time stamps, and required a username and password to access Taylor’s account. Taylor testified that he had not shared his login information and was logged into his account when Uber recorded the acceptance.

Other Arbitration Arguments

Taylor raised additional arguments against arbitration, including unconscionability and waiver. The court relied on its earlier holding that, if Taylor had agreed to arbitrate, the arbitration agreement clearly and unmistakably delegated those types of gateway issues to the arbitrator. The court therefore did not decide those arguments.

Request for More Discovery and Sanctions

Taylor asked for more discovery, asserting that Uber had not produced logs, metadata or records about his activity before or after the recorded acceptance. The court treated the request as one under Federal Rule of Civil Procedure 56(d), which permits additional discovery when a party identifies specific facts that further discovery could provide and shows that those facts are necessary to oppose summary judgment.

The court denied Taylor’s request for more discovery because his assertions were speculative. It also found that his written discovery requests were untimely because he served them less than a month before discovery closed, meaning Uber’s responses were not due until after the cutoff. The court was not persuaded that Taylor’s stated health-related difficulties justified the delay, noting his participation in other case activities. Taylor’s request for discovery sanctions was denied as well.

Ruling

The court found that the making of the arbitration agreement was not genuinely disputed and that Taylor had clicked “Yes, I agree” when prompted. The court granted Uber’s motion to compel arbitration. It denied Taylor’s request for more discovery and denied his request for discovery sanctions.

The court stayed further proceedings until arbitration ends and ordered the parties to file a joint status report every 180 days. The first report was due November 17, 2025.