Magana v. Doordash, Inc., 343 F. Supp. 3d 891

Background

Plaintiff Magana, a DoorDash delivery driver in San Jose, sued DoorDash and sought class relief and injunctive remedies; DoorDash moved to compel arbitration under its driver agreement.
Magana opposed, arguing (1) the FAA does not apply because he is a transportation worker engaged in interstate commerce, and (2) the arbitration agreement unlawfully bars pursuit of public injunctive relief.
The Agreement contains a class/collective/representative-action waiver but allows the arbitrator to award remedies otherwise available in court.
DoorDash sought a stay pending arbitration; Magana asked for dismissal to facilitate appellate review and moved for a protective order/corrective notice under Rule 23(d) based on a DoorDash driver-targeted company communication.
The court resolved the FAA applicability, the enforceability of the arbitration clause under California law (McGill), whether to stay or dismiss, and the Rule 23(d) request for corrective notice.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
FAA §1 transportation-worker exemption — is Magana exempt from the FAA?	Magana: DoorDash drivers facilitate interstate commerce and thus fall within §1 exemption.	DoorDash: Magana did not allege interstate travel; exemption is narrow and inapplicable.	Held: Exemption inapplicable — Magana is not shown to be a transportation worker engaged in interstate commerce.
Enforceability under California law — does the arbitration clause bar public injunctive relief and thus fail under McGill?	Magana: Agreement prohibits adjudication of public injunctive relief (via class/representative waiver), so it's invalid under McGill.	DoorDash: Complaint seeks labor-code injunctive relief primarily for employees (private), and the Agreement allows arbitrator to award remedies including public injunctions.	Held: Agreement is enforceable — Magana does not plead public injunctive relief, and the Agreement permits arbitrators to award such relief.
Stay vs dismissal under 9 U.S.C. §3 — should the case be stayed or dismissed pending arbitration?	Magana: Dismissal preferred to allow expedited appellate en banc review of circuit precedent.	DoorDash: Federal statute contemplates a stay; court may stay or dismiss but should stay here.	Held: Action is STAYED pending arbitration (court declines dismissal).
Rule 23(d) corrective notice / protective order re: DoorDash communication	Magana: Company email violated labor statutes and warranted corrective notice under Rule 23(d).	DoorDash: Email did not solicit opt-outs, was not confusing or misleading, and any impact on litigation is speculative.	Held: Motion denied — communication did not justify corrective notice or restrictions.

Key Cases Cited

Pinnacle Museum Tower Assn. v. Pinnacle Mkt. Dev. (US), LLC, 55 Cal.4th 223 (California Supreme Court) (party opposing arbitration bears burden to prove defenses)
Granite Rock Co. v. Int'l B'hd of Teamsters, 561 U.S. 287 (U.S. Supreme Court) (arbitration is based on consent; courts decide arbitrability unless delegated)
First Options of Chicago, Inc. v. Kaplan, 514 U.S. 938 (U.S. Supreme Court) (arbitrability principles)
Lifescan, Inc. v. Premier Diabetic Servs., Inc., 363 F.3d 1010 (9th Cir.) (FAA motion to compel standards)
Circuit City Stores, Inc. v. Adams, 532 U.S. 105 (U.S. Supreme Court) (FAA §1 interpretation and employee-exemption discussion)
Dean Witter Reynolds, Inc. v. Byrd, 470 U.S. 213 (U.S. Supreme Court) (courts must enforce arbitration agreements covering issues)
Chiron Corp. v. Ortho Diagnostic Sys., Inc., 207 F.3d 1126 (9th Cir.) (two-step test: validity and scope of agreement)
McGill v. Citibank, N.A., 2 Cal.5th 945 (California Supreme Court) (arbitration provisions cannot waive right to seek public injunctive relief)
Johnmohammadi v. Bloomingdale's, Inc., 755 F.3d 1072 (9th Cir.) (stay vs dismissal discretion under §3)
Domingo v. New England Fish Co., 727 F.2d 1429 (9th Cir.) (factors supporting restrictions on communications with class members)