Singh v. Uber Techs. Inc.
United States Court of Appeals for the Third Circuit
April 26, 2019, Argued; September 11, 2019, Filed
[*214] OPINION OF THE COURT
GREENAWAY, JR., Circuit Judge.
] Arbitration agreements are essentially contracts that predetermine that a dispute between parties will be decided by an arbitrator, rather than in court. In response to judicial hostility toward these types of contracts, Congress passed the Federal Arbitration Act ("FAA"), 9 U.S.C. §§ 1-16. The FAA places certain arbitration agreements on equal footing with all other contracts by requiring courts to enforce such agreements according [**2] to their terms. Section 2 provides that the FAA covers "a written provision in any maritime transaction or a contract evidencing a transaction involving commerce," id. § 2, but a provision in § 1 sets an outer limit, providing that "nothing" in the FAA "shall apply to contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce," id. § 1 ("§ 1"). This outer limit sets the stage for the case before us.
Jaswinder Singh brought this putative class action in the Superior Court of New Jersey, Monmouth County, on behalf of himself, and other similarly situated New Jersey Uber drivers. He alleged that Uber Technologies, Inc. ("Uber") misclassified them as independent contractors as opposed to employees, which resulted in their being deprived of overtime compensation, and having to incur business expenses for the benefit of Uber. Uber removed the case to federal court in the District of New Jersey. It then moved for the District Court to dismiss the case and compel Singh to have it decided by an arbitrator, on the basis of an agreement to arbitrate. Singh opposed the motion to compel arbitration on numerous grounds, one of which was that the District [**3] Court did not have the authority to compel arbitration under the FAA. He argued that, to the extent that he had an agreement with Uber, it fell within the ambit of the residual clause—the "any other class of workers" portion—of § 1. In the least, Singh asked that he be given the opportunity for discovery on the essential § 1 residual clause inquiry, which is whether the class of workers to which Singh belongs is "engaged in foreign or interstate commerce." Id.
The District Court granted the motion over Singh's objections. But it did not reach the engaged-in-interstate commerce inquiry. Instead, the Court ruled that Singh did not fall within the ambit of the residual clause of § 1 because that clause only extends to transportation workers who transport goods, not those who transport passengers. We disagree with this reading. Consistent with our longstanding precedent, we hold that ] the residual clause of § 1 may extend to a class of transportation workers who transport passengers, so long as they are engaged in interstate commerce or in work so closely related thereto as to be in practical effect part of it. We will therefore vacate the District Court's order compelling arbitration. In addition, [**4] because neither the Complaint nor incorporated documents suffice to resolve the engaged-in-interstate-commerce inquiry, we will remand this and the remaining issues to the District Court for further proceedings consistent with this opinion.Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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939 F.3d 210 *; 2019 U.S. App. LEXIS 27412 **; 2019 WL 4282185
JASWINDER SINGH, on behalf of himself and all those similarly situated, v. UBER TECHNOLOGIES INC Jaswinder Singh, Appellant
Prior History: [**1] On Appeal from the United States District Court for the District of New Jersey. (D.C. Civ. Action No. 3-16-cv-03044). District Judge: Honorable Freda L. Wolfson.
Singh v. Uber Techs. Inc., 235 F. Supp. 3d 656, 2017 U.S. Dist. LEXIS 12033 (D.N.J., Jan. 30, 2017)
transportation, arbitration, residuary clause, interstate commerce, employment contract, discovery, parties, delegation, commerce, transport passengers, drivers, arbitration agreement, railroad employee, transport goods, employees, belongs, motion to compel arbitration, decisions, exemption, quotation, marks, suggests, arbitration provision, incorporated document, contracts, includes, dispute resolution, passengers, extends, courts
Business & Corporate Compliance, Arbitration, Federal Arbitration Act, Arbitration Agreements, Scope, Civil Procedure, Judgments, Summary Judgment, Entitlement as Matter of Law, Defenses, Demurrers & Objections, Motions to Dismiss, Failure to State Claim, Orders to Compel Arbitration, Appeals, Standards of Review, De Novo Review, Governments, Legislation, Interpretation, Courts, Judicial Precedent