352 F. Supp. 3d 248
S.D. Ill.2018Background
- Plaintiffs (individuals with mobility disabilities and the organization WDOMI) allege Lyft discriminated by failing to provide sufficient wheelchair accessible vehicles (WAVs) and other reasonable accommodations.
- WDOMI sued on behalf of its members under the ADA, NYSHRL, and NYCHRL; individual plaintiff Lowell also sued under those statutes.
- Lyft moved to dismiss, arguing WDOMI lacks associational and organizational standing for some claims, and that plaintiffs are bound by Lyft's arbitration clause despite not signing the Terms of Service (TOS).
- Plaintiffs seek declaratory and injunctive relief (a remedial plan) and compensatory damages for some state-law claims.
- The court evaluated (1) associational and organizational standing for WDOMI, (2) enforceability of Lyft’s arbitration clause by estoppel, and (3) plausibility of ADA, NYSHRL, and NYCHRL claims under Rule 12(b)(6).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Associational standing for WDOMI | WDOMI’s members have been deterred from using Lyft; lawsuit furthers WDOMI’s purpose and does not require member participation | WDOMI’s claims/relief (compensatory damages under NYSHRL/NYCHRL) require individual member participation | WDOMI has associational standing generally, but not for NYSHRL and NYCHRL claims because the request for compensatory damages requires individual participation |
| Organizational standing for WDOMI | WDOMI diverted resources to assist constituents because of Lyft’s practices | WDOMI’s allegations are conclusory; diversion for litigation alone is insufficient | WDOMI lacks organizational standing: no plausible, concrete injury to the organization (alleged diversion is conclusory and litigation-related) |
| Enforcement of Lyft TOS arbitration clause by estoppel | Plaintiffs did not sign up for Lyft/TOS and did not receive benefits from the contract | Non-signatories receiving direct benefits from a contract can be estopped from avoiding arbitration | Estoppel does not apply: plaintiffs neither signed nor received direct or indirect benefits from Lyft’s TOS, so arbitration waiver is not enforced against them |
| Merits plausibility of discrimination claims (ADA, NYSHRL, NYCHRL) | Plaintiffs allege disability status, Lyft is a public accommodation, and Lyft denied equal access by not providing adequate WAVs | Lyft argues court cannot order WAVs and challenges status as public accommodation | ADA claim plausible and survives dismissal; NYSHRL claim survives; NYCHRL claim dismissed for failing to plausibly allege a violation given Lyft does offer some WAVs in NYC (alleged long waits insufficient) |
Key Cases Cited
- Hunt v. Wash. State Apple Advert. Comm'n, 432 U.S. 333 (1977) (three-part test for associational standing)
- Havens Realty Corp. v. Coleman, 455 U.S. 363 (1982) (organizational diversion-of-resources can be concrete injury)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility standard on motion to dismiss)
- Ragin v. Harry Macklowe Real Estate Co., 6 F.3d 898 (2d Cir. 1993) (organizational standing where defendant’s conduct forced organization to counteract practices)
- Olsen v. Stark Homes, Inc., 759 F.3d 140 (2d Cir. 2014) (organization’s pre-suit investigatory/resource expenditures can support standing)
- Reed v. 1-800-Flowers.com, 327 F. Supp. 3d 539 (E.D.N.Y. 2018) (injunctive relief under ADA can remedy access denials)