Harris v. Door Dash, Inc.
- Jacquelyn Corley
- 3:21-cv-09445
- U.S. District Court · Northern District of California
- 4
In Harris v. Door Dash, Inc., Judge Corley granted Door Dash’s motion to compel arbitration of Harris’s Fair Labor Standards Act claims and stayed the case.
Kevin Jerome Harris and Door Dash, Inc. The court case is stayed, and Harris’s Fair Labor Standards Act claims must proceed in arbitration under the agreement.
What happened
Kevin Jerome Harris sued Door Dash, Inc., alleging that he was not paid required overtime and was paid less than the minimum wage while making deliveries. Harris proceeded without a lawyer. Door Dash asked the court to require arbitration instead of continuing the case in court.
The court found that Harris had agreed to Door Dash’s arbitration terms when he created a 2020 account. Delivery records linked the deliveries involved in the lawsuit to that account, and the arbitration agreement expressly covered Fair Labor Standards Act claims.
The court granted Door Dash’s motion to compel arbitration and stayed the claims in court while arbitration proceeds. Judge Jacquelyn Scott Corley issued the order.
The detailed version
- Harris v. Door Dash, Inc. · No. 3:21-cv-09445
- Jacquelyn Corley
- May 9, 2023
Background
Kevin Jerome Harris sued Door Dash, Inc. under the Fair Labor Standards Act. He alleged that he worked as a “dasher” between November 23, 2020, and November 29, 2021; worked weeks exceeding 40 hours without receiving overtime pay; and received less than the minimum wage on one day.
Harris argued that he had not agreed to Door Dash’s arbitration terms because he used an account created in 2019. Door Dash acknowledged that Harris had created a 2019 account but argued that he used a separate 2020 account for the deliveries involved in the lawsuit. Because Door Dash initially did not provide evidence supporting that assertion, the court requested additional evidence and briefing. Door Dash then submitted delivery records associating all deliveries during the relevant period with the 2020 account. Harris did not submit additional briefing or evidence.
Court’s Analysis
The Federal Arbitration Act generally requires courts to enforce arbitration agreements, subject to ordinary contract defenses. On a motion to compel arbitration, the court considered whether a valid arbitration agreement existed and whether that agreement covered the dispute.
The court applied the summary-judgment standard to the contract-formation issue. It found no genuine dispute about whether Harris agreed to arbitrate before making the deliveries at issue. Harris created the 2020 account, more than 400 deliveries were associated with that account, the deliveries covered the period alleged in the complaint, and Door Dash required agreement to the arbitration terms to create the account.
The court also found that the agreement covered the dispute. The agreement applied to disputes concerning Harris’s services, payments, and other aspects of his relationship with Door Dash, and it expressly included Fair Labor Standards Act claims.
Disposition
The court granted Door Dash’s motion to compel arbitration. The claims against Door Dash in the federal court case were stayed pending resolution of the arbitration. The court also ordered Door Dash to file a status update about the arbitration by November 16, 2023. Judge Jacquelyn Scott Corley stated that the order resolved Docket No. 21.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.