Brian Washington v. State Farm Fire and Casualty Company, Lyft, and Daniel Steilberg
2025-CA-0047
| La. Ct. App. | Jun 12, 2025Background
- Brian Washington (aka Secret Washington), acting pro se, sued State Farm, Lyft, and the Lyft driver Daniel Steilberg, alleging injuries from two incidents involving Steilberg's vehicle during a Lyft ride on December 14, 2021.
- After filing suit, the district court granted Lyft's motion to compel arbitration and stayed the court proceedings.
- Washington repeatedly sent harassing and inappropriate emails to opposing counsel and failed to comply with the court-ordered arbitration process, including later withdrawing her deposit and alleging fraud.
- The district court imposed communication restrictions, ordered Washington to comply with arbitration, and, after further violations and noncompliance, granted defendants' motion for contempt and dismissed Lyft with prejudice.
- Washington appealed, contesting the dismissal and alleging due process violations, fraud in the arbitration process, and manifest injustice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Dismissal based on arbitration orders | Fraudulent notarization and misrepresentation | No timely appeal of interlocutory orders | Not reviewable on appeal; no jurisdiction |
| Alleged manipulation of arbitration process | Arbitration manipulated, contract falsified | Arbitration never commenced due to plaintiff | Not supported; plaintiff canceled arbitration |
| Due process violation in dismissal | No fair opportunity to present evidence | Multiple hearing opportunities provided | No due process violation found |
| Manifest injustice of district court dismissal | Fraud & retaliation rendered dismissal unjust | No fraud shown, arbitration not held | No evidence of manifest injustice |
Key Cases Cited
- Collins v. Prudential Ins. Co. of Am., 752 So. 2d 825 (La. 2000) (arbitration orders are interlocutory, not appealable absent irreparable harm)
- Jones v. Cisneros, 315 So. 3d 959 (La. App. 4 Cir. 2021) (standard of review for dismissal is abuse of discretion/manifest error)
- Glazer v. Glazer, 390 So. 3d 765 (La. App. 4 Cir. 2024) (appeal of interlocutory decision may be converted to writ only if timely)
- Lirette v. Adams, 382 So. 3d 122 (La. App. 4 Cir. 2023) (conversion to writ requires filing within thirty days)