Cunningham v. Lyft, Inc., 17 F.4th 244

Background

Plaintiffs are Massachusetts Lyft drivers who accepted Lyft's 2018 Terms of Service containing a bilateral arbitration clause with a class-action waiver; plaintiffs did not opt out.
Plaintiffs sued claiming misclassification and sought preliminary injunctive relief (including a "public injunction") on behalf of themselves and putative class members; no class had been certified.
Lyft moved to compel arbitration under the Federal Arbitration Act (FAA); the district court denied the motion and also denied plaintiffs' preliminary injunctive requests.
Key factual disputes concerned whether drivers are a "class of workers engaged in ... interstate commerce" under FAA §1 because (a) they transport passengers to/from Logan Airport and (b) a small percentage of trips cross state lines (<2% nationwide; <0.5% in MA).
The First Circuit considered whether the §1 transportation-worker exemption applies, treating Yellow Cab and Circuit City precedent as central, and evaluated the district court's denials of both the arbitration motion and the preliminary injunctions.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Lyft drivers are a "class of workers engaged in interstate commerce" under FAA §1 because they take passengers to/from Logan Airport	Airport trips integrate drivers into interstate commerce (part of passengers' interstate journeys)	Airport pickups are like local taxi service (Yellow Cab): drivers perform local, intrastate legs, not integral interstate transportation	Held: No — Logan trips are analogous to Yellow Cab's local fares and do not make the class engaged in interstate commerce
Whether occasional interstate trips (a small % of rides) bring the class within §1	Occasional interstate trips (many drivers sometimes cross state lines) suffice to qualify the class	Interstate trips are rare; the class is primarily intrastate and §1 should be narrowly construed	Held: No — the class is primarily intrastate; §1 exception is narrow and aimed at transportation workers focused on interstate movement
Whether the arbitration agreement must be enforced	Plaintiffs: FAA §1 applies so arbitration inapplicable; thus district court correctly refused to compel arbitration	Lyft: FAA applies; arbitration clause (signed TOS) is enforceable	Held: FAA applies and the district court's denial is reversed — arbitration compelled
Whether the district court erred in denying preliminary injunctions (including a "public injunction")	Plaintiffs: public interest and potential harms to other drivers justify injunction pending resolution	Lyft: plaintiffs failed to show irreparable harm and lack standing to seek classwide public relief absent class certification	Held: Denials affirmed — plaintiffs showed no irreparable harm and cannot obtain public, classwide injunctive relief absent a certified class

Key Cases Cited

Epic Sys. Corp. v. Lewis, 138 S. Ct. 1612 (2018) (FAA presumption favoring arbitration as a matter of contract law)
AT&T Mobility LLC v. Concepcion, 563 U.S. 333 (2011) (courts must enforce arbitration agreements according to their terms)
Circuit City Stores, Inc. v. Adams, 532 U.S. 105 (2001) (§1 FAA exemption limited to transportation workers)
United States v. Yellow Cab Co., 332 U.S. 218 (1947) (distinguishes local taxi service from interstate transportation integral to interstate commerce)
Waithaka v. Amazon.com, Inc., 966 F.3d 10 (1st Cir. 2020) (interpreting §1 in the context of last-mile delivery drivers)
Capriole v. Uber Techs., Inc., 7 F.4th 854 (9th Cir. 2021) (rideshare drivers not within §1 where interstate trips are infrequent)
Int'l Bhd. of Teamsters Local Union No. 50 v. Kienstra Precast, Inc., 702 F.3d 954 (7th Cir. 2012) (class of drivers held within §1 despite small % of interstate trips)
Next Step Med. Co., Inc. v. Johnson & Johnson Int'l, 619 F.3d 67 (1st Cir. 2010) (general rule that arbitration supersedes need for district-court consideration of merits; limited exceptions for interim emergency relief)