Mandeng v. Uber Technologies, Inc.
Civil Action No. 2024-3488
D.D.C.Jun 25, 2025Background
- Jonathan Camille Mandeng, a former Uber driver, filed a pro se complaint in D.C. Superior Court alleging Uber mistreated drivers and unlawfully withheld wages.
- Mandeng sought injunctive relief against Uber’s alleged practices and requested $150,000 in damages.
- Uber removed the case to federal court, citing diversity jurisdiction due to the amount in controversy and parties' citizenship.
- Uber moved to compel arbitration, referencing agreements Mandeng signed that contained arbitration provisions covering all disputes related to his employment.
- These agreements provided a clear 30-day opt-out option from arbitration, but Uber presented evidence Mandeng did not opt out.
- Mandeng did not file any opposition to Uber’s motion to compel arbitration despite receiving notice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Mandeng’s claims must be arbitrated | Court should address his claims | Arbitration agreement is binding | Must be arbitrated |
| Existence of valid arbitration agreement | Not expressly contested | Agreement valid and assented to | Valid agreement exists |
| Who decides arbitrability (gateway issues) | Not expressly contested | Arbitrator given this authority | Arbitrator decides |
| Stay of proceedings pending arbitration | Not addressed | Requested statutory stay | Granted stay |
Key Cases Cited
- Coinbase, Inc. v. Suski, 602 U.S. 143 (2024) (arbitration agreements as contracts; parties may delegate arbitrability)
- Henry Schein, Inc. v. Archer & White Sales, Inc., 586 U.S. 63 (2019) (court may not decide arbitrability when delegated)
- First Options of Chi., Inc. v. Kaplan, 514 U.S. 938 (1995) (scope of delegation of arbitrability is a matter of contract)
- Smith v. Spizzirri, 601 U.S. 472 (2024) (district courts must stay proceedings pending arbitration if a dispute is arbitrable)
- Commc’ns Workers of Am. v. AT&T Inc., 6 F.4th 1344 (D.C. Cir. 2021) (clear delegation of arbitrability issues to arbitrator)
- Mohamed v. Uber Techs., Inc., 848 F.3d 1201 (9th Cir. 2016) (similar Uber arbitration provision validly delegates arbitrability)