Broadnax v. Lyft, Inc.
2:25-cv-00190
D. Nev.Jul 8, 2025Background
- Rafford Broadnax became a Lyft driver by creating a driver account and agreeing to Lyft's Terms of Service, which included an arbitration clause.
- Lyft later deactivated Broadnax's driver account.
- Broadnax filed a lawsuit alleging discriminatory deactivation, employee misclassification, and several other workplace claims.
- Lyft moved to compel arbitration based on the arbitration clause in its Terms of Service and to stay the case pending arbitration.
- Broadnax opposed, challenging the enforceability and applicability of the arbitration clause.
- The court considered whether the disputes must be resolved in arbitration and whether to stay the action.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Enforceability of Arbitration Agreement | Did not physically sign or receive arbitration clause | Electronic acknowledgement sufficient | Enforceable, electronic consent allowed |
| FAA Exemption for Transportation Workers | Exempt as transportation worker | Rideshare drivers not covered by exemption | Not exempt; must arbitrate under FAA |
| Unconscionability of Arbitration Clause | Clause is unconscionable (no specifics identified) | Mutual, clear, opt-out provision present | Not unconscionable; valid and enforceable |
| Scope of Arbitration (Coverage of Claims) | Claims not covered by arbitration agreement | Broad clause covers all claims asserted | Arbitrator decides; all claims likely covered |
Key Cases Cited
- Nguyen v. Barnes & Noble Inc., 763 F.3d 1171 (9th Cir. 2014) (sets standard for court's limited role when deciding motions to compel arbitration)
- Republic of Nicaragua v. Standard Fruit Co., 937 F.2d 469 (9th Cir. 1991) (court does not consider merits in arbitration motion)
- Brennan v. Opus Bank, 796 F.3d 1125 (9th Cir. 2015) (incorporation of AAA rules delegates arbitrability decisions to the arbitrator)
- Capriole v. Uber Techs., Inc., 7 F.4th 854 (9th Cir. 2021) (rideshare drivers not exempt from FAA as transportation workers)
