Lowell v. Lyft, Inc.

Background and procedural posture

Harriet Lowell and Westchester Disabled on the Move, Inc. asked the court to certify classes under Federal Rule of Civil Procedure 23. Their claims alleged that Lyft’s policies, practices, and procedures categorically prevented wheelchair-accessible vehicle service in certain regions, denying people who require those vehicles equal access to Lyft’s transportation services under Title III of the Americans with Disabilities Act. The magistrate judge recommended granting the class-certification motion in part and denying it in part and certifying three proposed classes. Lyft filed objections, principally challenging the plaintiffs’ constitutional standing and the proposed classes’ compliance with Rule 23.

Standing

The court rejected Lyft’s argument that the plaintiffs lacked Article III standing. Standing requires an injury in fact, a connection between the injury and the challenged conduct, and a likelihood that a favorable decision would remedy the injury. The court concluded that Lowell had shown, by a preponderance of the evidence, a plausible intention to use Lyft’s transportation services in the future if the alleged policies and practices were changed. The court relied on her statements that she would use Lyft if reliable WAV service became available and that she had been deterred from using Lyft because she knew it did not offer services to mobility-impaired individuals.

The court reached substantially the same conclusion for WDOMI based on declarations from its members stating that they would use Lyft if it provided accessible services. The court also found redressability because at least some requested relief—such as removing the categorical block on WAV service in the regions at issue—could address the alleged injury. It therefore adopted the finding that the plaintiffs had standing and denied Lyft’s request to enter judgment in its favor for lack of standing.

Class definitions and Rule 23

The court rejected Lyft’s argument that the proposed classes included people without standing. It held that the named plaintiffs’ standing was enough to confer standing on the entire class and that the proposed definitions limited membership to people denied equal access to Lyft’s transportation services.

The court adopted the magistrate judge’s findings that the proposed classes satisfied Rule 23’s requirements. The plaintiffs established numerosity through statistical data and hundreds of declarations; commonality because they challenged a uniform policy concerning WAV service; typicality because the claims arose from the same alleged course of conduct; and adequacy because Lowell and WDOMI sought the same relief as the proposed classes and had no identified conflict with class members. The court also found that the class definitions used objective criteria and that the proposed injunctive relief would benefit the class members, satisfying Rule 23(b)(2).

The court emphasized that whether Lyft’s categorical preclusion of WAV service violated the Americans with Disabilities Act was a merits question and was not decided in ruling on class certification. The court modified the second and third class definitions to clarify that WDOMI did not assert claims under the New York State Human Rights Law.

Disposition

Judge Halpern overruled Lyft’s objections and adopted the report and recommendation in its entirety except for the stated modifications to the class definitions. The court certified these three classes:

The court excluded people who had downloaded the Lyft app, had brought separate litigation against Lyft concerning its failure to serve people with disabilities, or were residents of Ohio State University or the University of Texas at Austin who did not leave those campuses. It appointed Finkelstein, Blankinship, Frei-Pearson & Garber, LLP, Morgan & Morgan, P.C., and Michael Hellman of ADA compliance specialists as class counsel. It granted the request to maintain specified proposed findings and conclusions under seal and directed the clerk to terminate the pending motions identified in the order.