Wells v. Maplebear Inc.

Background

Lance C. Wells, a former Instacart “Shopper,” sued Maplebear Inc., doing business as Instacart. Wells alleged that Instacart interfered with his freedom of speech by coercing him into signing a settlement agreement with a broad non-disparagement clause. The clause restricted Wells from making or encouraging others to make disparaging or derogatory statements about Instacart. The agreement provided for a $3,000 payment to Wells.

Wells had previously sued Instacart in Arizona state court after Instacart deactivated his Shopper account. That dispute ended in a settlement. After Instacart waited six days to reinstate his account, Wells filed another lawsuit in federal court in Arizona. He argued there that the non-disparagement clause violated the First Amendment and that Instacart had engaged in discriminatory practices creating a hostile work environment. The Arizona district court dismissed the First Amendment claim with prejudice and treated the discrimination claim as subject to mandatory arbitration.

Wells then filed this action under 42 U.S.C. § 1983, the federal civil-rights statute that allows certain claims against government actors. He again challenged the non-disparagement clause and added arguments that he had signed the settlement agreement under economic pressure and because of misrepresentations by Instacart. Instacart moved to dismiss.

Judicial Notice

The court granted Instacart’s request to take judicial notice of twelve documents from the earlier Arizona litigation. Judicial notice allows a court to consider facts that are not reasonably disputed, including public court filings, without treating a motion to dismiss as a motion for summary judgment based on disputed facts.

Claim Preclusion

The court applied claim preclusion, also called res judicata. This doctrine prevents a party from bringing a later case based on claims that were already resolved in an earlier case. The court explained that claim preclusion requires three elements: the two cases must involve the same claims, the earlier case must have ended in a final judgment on the merits, and the parties must be the same or legally connected.

The court found all three requirements satisfied. First, both cases arose from the same events and centered on the settlement agreement’s non-disparagement clause and Wells’s related speech rights. Changing the legal label to a § 1983 claim, adding economic-duress and misrepresentation theories, or offering new arguments about state-actor status did not change that conclusion because those matters could have been raised in the earlier case.

Second, the Arizona court’s dismissal of the First Amendment claim with prejudice was a final judgment on the merits. Third, the parties in both cases were Wells and Instacart. The court also found that Instacart’s claim-preclusion argument did not depend on disputed facts.

Disposition

The court granted Instacart’s motion to dismiss this action as barred by claim preclusion. It denied Wells’s motion for relief from automatic referral to alternative dispute resolution as moot. Because amendment would be futile, the court dismissed the action without leave to amend, directed that a separate judgment enter, and ordered the case closed.