Austin v. Lyft, Inc.

Background

George Jarvis Austin alleged in his First Amended Complaint that Lyft discriminated against him based on race in connection with a background check performed as part of Lyft’s hiring process. He asserted claims for intentional discrimination, defamation, and deceit. Lyft moved to compel arbitration and to dismiss or, alternatively, stay the action.

Arbitration Agreement

Under the Federal Arbitration Act, a court must require arbitration when an arbitration agreement exists and covers the dispute. The court found that Austin and Lyft executed an arbitration agreement on December 1, 2021, through the April 1, 2021 version of Lyft’s Terms of Service. The agreement stated that disputes between the parties would be resolved exclusively through binding arbitration and covered disputes relating to background checks, discrimination, fraud, and defamation.

The court therefore found that Austin had agreed to arbitrate each claim asserted against Lyft. It granted Lyft’s request to compel arbitration.

Dismissal

The court explained that although the Federal Arbitration Act provides for a stay when a claim must be arbitrated, the Ninth Circuit allows a court to dismiss an action when all claims are subject to arbitration. Because all of Austin’s claims were covered by the arbitration agreement, the court granted Lyft’s request for dismissal.

Disposition

The court granted Lyft’s motion to compel arbitration and dismissed the action without prejudice to Austin’s pursuing arbitration of his claims. The court also vacated the scheduled hearing.