Osvatics v. Lyft, Inc.

Osvatics v. Lyft, Inc.

Opinion

 [*4]  MEMORANDUM OPINION

Plaintiff Cassandra Osvatics worked as a driver for the ride-sharing company Lyft, Inc. in the Washington, D.C. metropolitan area from November of 2015 to June of 2018. (See Compl., ECF No. 2, ¶¶ 7-10.) In May of 2020, Osvatics filed a putative class-action lawsuit against Lyft, alleging that Lyft was engaged in a continuous violation of District of Columbia law by failing to provide paid sick leave to its drivers in the District. (See id. ¶¶ 79, 90-99.) According to Lyft, [**2]  however, Osvatics had agreed to the company's Terms of Service for its drivers, which require any disputes between Lyft and its drivers to be resolved by arbitration on an individual basis rather than through the filing of a lawsuit. (See Decl. of Neil Shah in Supp. of Def.'s Mot. ("Shah Decl."), ECF No. 6-2, ¶¶ 8, 13.)

Before this Court at present is Lyft's motion to compel individual arbitration of Osvatics's claim and to stay the instant proceedings pending any arbitration between the parties. (See Def.'s Mot. to Compel Individual Arbitration and Stay Proceedings Pending Arbitration, ECF No. 6; Def.'s Mem. in Supp. of Mot. to Compel Individual Arbitration and Stay Proceedings Pending Arbitration ("Def.'s Mot."), ECF No. 6-1.) Lyft contends that the arbitration agreement and the associated class waiver in its Terms of Service are valid, and thus the Federal Arbitration Act ("FAA"), 9 U.S.C. § 1 et seq., requires this Court to enforce the arbitration agreement by compelling Osvatics to submit this dispute to individual arbitration. (See Def.'s Mot. at 9-10.)¹ Osvatics responds, in part, that the FAA does not apply to her agreement with Lyft given section 1 of the statute, which provides that the "contracts of employment" [**3]  of any "class of workers engaged in . . . interstate commerce" are categorically exempt from the FAA's coverage. (See Pl.'s Opp'n to Def.'s Mot. to Compel Individual Arbitration and Stay Proceedings Pending Arbitration ("Pl.'s Opp'n"), ECF No. 20, at 19 (quoting 9 U.S.C. § 1).)

On March 31, 2021, this Court issued an Order that GRANTED Lyft's motion to compel arbitration. (See Order, ECF No. 47.) This Memorandum Opinion explains the reasons for that Order. In short, and  [*5]  as explained fully below, this Court has concluded that Osvatics is bound by Lyft's arbitration agreement and that the section 1 exemption does not apply to rideshare drivers such as Osvatics. Therefore, the FAA requires this Court to compel arbitration of the instant dispute.

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