Haider v. Lyft, Inc.
- Jed Rakoff
- 1:20-cv-02997
- U.S. District Court · Southern District of New York
- 3
In Haider v. Lyft, Judge Nathan granted amendment and administratively denied three motions without prejudice pending further arbitration briefing.
The drivers and Lyft, Inc.; the order allowed the drivers to amend their complaint and deferred consideration of Lyft’s state-law arbitration and dismissal motions, as well as the drivers’ discovery request.
What happened
In Haider v. Lyft, Inc., the drivers asked to amend their complaint while the court considered Lyft’s request to compel arbitration, Lyft’s request to dismiss, and the drivers’ request for discovery.
The court said the parties needed to address whether California law governed the arbitration dispute and whether an earlier decision involving the same parties prevented the drivers from opposing arbitration under state law. The court had already denied Lyft’s request to compel arbitration under the Federal Arbitration Act in a separate opinion.
Judge Alison J. Nathan granted the drivers’ motion to amend. The court administratively denied without prejudice Lyft’s state-law arbitration motion and dismissal motion, and the drivers’ discovery motion, while requiring further briefing and setting deadlines for an amended complaint and any renewed motions.
The detailed version
- Haider v. Lyft, Inc. · No. 1:20-cv-02997
- Jed Rakoff
- Mar. 31, 2021
Background
The court considered four motions: Lyft’s motion to compel arbitration, Lyft’s motion to dismiss, the drivers’ motion for discovery, and the drivers’ motion to amend their complaint. The court noted that, in a separate opinion and order, it had denied Lyft’s request to compel arbitration under the Federal Arbitration Act.
Amendment
The court granted the drivers leave to amend. Under Rule 15, courts generally allow an amendment unless there is undue delay, bad faith, repeated failure to fix earlier problems, unfair prejudice, futility, or another compelling reason. Lyft did not argue that the proposed amendment would be futile, and the court did not infer bad faith from the timing. Because the case was at an early stage and no scheduling order had been entered, the court found that amendment would not unfairly prejudice Lyft.
Further arbitration briefing
The court required additional briefing on Lyft’s request to compel arbitration under state law. It identified two issues that the existing briefs did not adequately address. First, the court questioned whether Lyft’s terms of service required California law to apply. Second, the parties had not addressed whether an earlier decision involving the same parties should prevent Islam from opposing arbitration under state law. The court said that allowing amendment would not cause significant additional delay because it would defer consideration of the motions pending the additional briefing.
Rulings and deadlines
The court administratively denied without prejudice Lyft’s motion to compel arbitration under state law, Docket No. 14; administratively denied without prejudice Lyft’s motion to dismiss, Docket No. 20; administratively denied without prejudice the drivers’ motion for discovery, Docket No. 32; and granted the drivers’ motion to amend, Docket No. 52. The amended complaint was due by April 30, 2021. Any renewed state-law arbitration or dismissal motion was due by May 21, 2021, followed by specified response and reply deadlines. The court stated that it would set a discovery schedule after deciding any renewed arbitration or dismissal motion.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.