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RAZAK v. UBER TECHNOLOGIES, INC.
2:16-cv-00573
E.D. Pa.
Jul 30, 2024
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Background

  • Plaintiffs, three UberBLACK drivers in Philadelphia (2013–2018), allege Uber misclassified them as independent contractors under the FLSA, PMWA, and WPCL, denying them employee benefits.
  • The case began in 2016 and has involved extensive discovery, two trials, and appellate review by the Third Circuit, which reversed an initial grant of summary judgment for Uber, citing disputed material facts.
  • Both jury trials resulted in hung juries, unable to unanimously determine if UberBLACK drivers were employees or independent contractors under applicable law.
  • The key factual dispute centers on Uber's level of control over drivers versus the drivers’ flexibility and autonomy in choosing when and how to work.
  • Post-trial motions included competing requests for judgment as a matter of law, a new trial, and other relief, with both sides arguing the evidence favored their position.
  • The Court, weighing futility and the repeated deadlocks, dismissed the case with prejudice under its inherent authority to manage its docket, alternatively granting Uber’s Rule 50(b) motion.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Employee vs. Independent Contractor Classification UberBLACK drivers are employees based on Uber control Drivers have autonomy; many controls due to local law Repeated deadlock: Court finds further trials futile; dismisses case with prejudice
Appropriateness of Judgment as a Matter of Law (Rule 50(b)) Sufficient evidence for jury to find employment status No reasonable jury could find for Plaintiffs Defendants’ motion granted in the alternative: evidence does not support finding Plaintiffs as employees
Fairness of Jury Pool Second jury pool unrepresentative of Philadelphia Geographic disparity is not a basis for challenge No grounds for a new trial based on jury composition
Request for Declaratory Relief Plaintiffs seek future relief after UberBLACK’s exit No ongoing controversy as UberBLACK no longer operates Dismissed: No likelihood of future injury

Key Cases Cited

  • Link v. Wabash R.R. Co., 370 U.S. 626 (1962) (recognizing district courts’ inherent authority to control their dockets, including sua sponte dismissal)
  • Eash v. Riggins Trucking Inc., 757 F.2d 557 (3d Cir. 1985) (discussing the breadth of the district court’s inherent powers)
  • Donovan v. DialAmerica Mktg., Inc., 757 F.2d 1376 (3d Cir. 1985) (setting forth economic reality factors for employment status)
  • Williams v. Jani-King of Philadelphia Inc., 837 F.3d 314 (3d Cir. 2016) (WPCL test for employee status)
  • Gulf Oil Co. v. Bill's Farm Center, Inc., 449 F.2d 778 (8th Cir. 1971) (discretion to avoid endless retrials)
  • Parkway Garage, Inc. v. City of Philadelphia, 5 F.3d 685 (3d Cir. 1993) (limits of JNOV under Rule 50)
  • Bonjorno v. Kaiser Aluminum & Chemical Corp., 752 F.2d 802 (3d Cir. 1984) (conflicting evidence precludes judgment notwithstanding jury verdict)
Read the full case

Case Details

Case Name: RAZAK v. UBER TECHNOLOGIES, INC.
Court Name: District Court, E.D. Pennsylvania
Date Published: Jul 30, 2024
Docket Number: 2:16-cv-00573
Court Abbreviation: E.D. Pa.