Alexander v. Lyft

CourtSuperior Court of Delaware
DecidedMarch 4, 2025
DocketN24C-09-064 FJJ
StatusPublished

This text of Alexander v. Lyft (Alexander v. Lyft) is published on Counsel Stack Legal Research, covering Superior Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Alexander v. Lyft, (Del. Ct. App. 2025).

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

MARCIA ALEXANDER, ) ) Plaintiff, ) v. ) ) C.A. No. N24C-09-064 FJJ LYFT, INC. and ) TYLIEF CHRISTOPHER, ) ) Defendants. )

Submitted: February 19, 2025 Decided: March 4, 2025

OPINION AND ORDER

Defendant Lyft, Inc.’s Motion to Dismiss Count II of Plaintiff’s Complaint Pursuant to Superior Court Civil Rule 12(b)(1) GRANTED

Jason D. Warren, Esquire, Shelsby & Leoni, Wilmington, Delaware, Attorneys for Plaintiff, Marcia Alexander.

Sean Elman, Esquire and Christian J. Singewald, Esquire, White & Williams, LLC, Wilmington, Delaware, Attorney for Defendant Lyft, Inc.

Jones, J. On September 26, 2022, Plaintiff, Marcia Alexander (“Alexander”), was

driving for Lyft, Inc (“Lyft”) when she was attacked by Defendant, Tylief

Christopher (“Christopher”), who was a passenger in Alexander’s car. Alexander

has filed the instant Complaint1 which includes three counts. In Count I,

Alexander seeks an election of personal injuries over workman’s compensation

benefits against Lyft because Lyft did not provide workman’s compensation

insurance to her. Count II involves direct claims of negligence against Lyft.

Count III alleges claims against Christopher.

Lyft has moved to dismiss Count II arguing that the Court lacks subject

matter jurisdiction because the matter is subject to binding arbitration pursuant to

an arbitration agreement between Alexander and Lyft. Alexander opposes Lyft’s

motions. For the reasons stated herein, Lyft’s Motion to Dismiss is GRANTED.

STANDARD OF REVIEW

Lyft moves to dismiss based on Superior Court Civil Rule 12(b)(1), claiming

that the Court lacks subject matter jurisdiction over the claims in the Complaint. It

is well-settled in Delaware that the power to compel arbitration lies exclusively with

the Court of Chancery.2 This Court has held, however, that is has jurisdiction to

determine whether a valid and enforceable arbitration agreement exists for purposes

1 Docket Item (“D.I.”) 1. 2 10 Del. C. §5701.

2 of determining whether it has subject matter jurisdiction.3 In reviewing such a

motion, the Court may consider matters outside the pleadings, such as testimony

and affidavits.4

On a motion to dismiss under Rule 12(b)(1), the Court must accept every

well-pled allegation as true and draw all reasonable inferences in the non-movant’s

favor.5 A motion to dismiss should be denied unless it appears to a “reasonable

certainty” that the plaintiff would not be entitled to relief under any set of facts that

could be proved to support them.6

DISCUSSION

Both the Federal Arbitration Act (“FAA”)7 and Delaware’s Uniform

Arbitration Act8 recognize the validity and enforceability of agreements to settle

disputes through arbitration rather than by litigation in courts. The FAA

“establishes ‘a liberal federal policy favoring arbitration.’”9 Similarly, the public

policy of Delaware “favors resolution of disputes through arbitration.”10 The

3 Jones v. 810 Broom Street Operations, LLC, 2014 WL 1347746, at *1 (Del. Super. April 7, 2014); see also Aquila of Delaware, Inc. v. Wilmington Trust Company, 2011 WL 4908406, at *1 (Del. Super. Oct. 10, 2011). 4 Cecilia Abernathy, et al. v. Brandywine Urology Consultants, P.A., 2021 WL 211144, at *1 (Del. Super. Jan. 21, 2021). 5 Donald H. Loudon, Jr., v. Archer-Daniels-Midland Co., et al., 700 A.2d 135, 140 (Del. 1997). 6 Id. 7 9 U.S.C. § 2. 8 10 Del. C. § 5701. 9 Epic Sys. Corp. v. Lewis, 584 U.S. 497, 506 (2017) (quoting Moses H. Cone Memorial Hospital v. Mercury Const. Corp., 460 U.S. 1, 24 (1983)). 10 Graham v. State Farm Mut. Auto Ins. Co., 565 A.2d 908, 911 (Del. 1989) (citing Pettinaro Constr. Co. v. Harry C. Partridge, Jr. & Sons, Inc., 408 A.2d 957, 961 (Del. Ch. 1979)).

3 Court’s first task is to determine whether a valid agreement to arbitrate existed

between Alexander and Lyft.

Under Delaware law, contract formation requires mutual assent, meaning a

complete meeting of the minds of the parties.11 No agreement to arbitrate exists

unless there is a clear expression of such an intent.12 Establishing a meeting of the

minds and mutual assent turns on the existence of “reasonable notice to each

contracting party of the contractual terms.”13

There seems little doubt that the parties agreed to binding arbitration. In

fact, Plaintiff makes no real argument to the contrary. The parties’ agreement

provides in relevant part:

(a) Agreement to Binding Arbitration Between You and Lyft. YOU AND LYFT MUTUALLY AGREE TO WAIVE OUR RESPECTIVE RIGHTS TO RESOLUTION OF DISPUTES IN A COURT OF LAW BY A JUDGE OR JURY AND AGREE TO RESOLVE ANY DISPUTE BY ARBITRATION, as set forth below. This agreement to arbitrate (“Arbitration Agreement”) is governed by the Federal Arbitration Act (“FAA”); but if the FAA is inapplicable for any reason, then this Arbitration Agreement is governed by the laws of the State of Delaware, including Del. Code tit. 10, § 5701 et seq., without regard to choice of law principles. … Except as expressly provided below, this Arbitration Agreement applies to all Claims (defined below) between you and Lyft,

11 United Health Alliance, LLC v. United Medical, LLC, 2913 WL 6383026, at *6 (Del. Ch. Nov. 27, 2013). 12 Id. 13 Payne v Samsung Electronics America, Inc. et al, 2024 WL 726907 (Del. Super.2024); Noble v. Samsung Electronics America, Inc. 682 F. App’x. 113, 116 (3d. Cir. 2017)

4 …..

Except as expressly provided below, ALL DISPUTES AND CLAIMS BETWEEN US (EACH A “CLAIM” AND COLLECTIVELY, “CLAIMS”) SHALL BE EXCLUSIVELY RESOLVED BY BINDING ARBITRATION SOLELY BETWEEN YOU AND. …..

BY AGREEING TO ARBITRATION, YOU UNDERSTAND THAT YOU AND LYFT ARE WAIVING THE RIGHT TO SUE IN COURT OR HAVE A JURY TRIAL FOR ALL CLAIMS, EXCEPT AS EXPRESSLY OTHERWISE PROVIDED IN THIS ARBITRATION AGREEMENT. This Arbitration Agreement is intended to require arbitration of every claim or dispute that can lawfully be arbitrated, except for those claims and disputes which by the terms of this Arbitration Agreement are expressly excluded from the requirement to arbitrate.

(g) Exceptions to Arbitration. This Arbitration Agreement shall not require arbitration of the following types of claims:

(3) Claims for workers’ compensation, state disability insurance and unemployment insurance benefits;14 It is clear that the parties intended any claim belonging to Alexander as to Lyft be

subject to binding arbitration absent one of the specific enumerated exceptions

outlined in the agreement which do not apply to Count II.

Having determined that there is an agreement between the parties regarding

binding arbitration, the question then becomes who decides what claims are within

14 D.I. 10, Exhibit (“Ex.”) 1, Lyft’s Terms of Service.

5 the scope of the arbitration agreement. The arbitration agreement at issue further

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Related

Loudon v. Archer-Daniels-Midland Co.
700 A.2d 135 (Supreme Court of Delaware, 1997)
Graham v. State Farm Mutual Automobile Insurance
565 A.2d 908 (Supreme Court of Delaware, 1989)
Pettinaro Construction Co. v. Harry C. Partridge, Jr., & Sons, Inc.
408 A.2d 957 (Court of Chancery of Delaware, 1979)
Epic Systems Corp. v. Lewis
584 U.S. 497 (Supreme Court, 2018)

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Alexander v. Lyft, Counsel Stack Legal Research, https://law.counselstack.com/opinion/alexander-v-lyft-delsuperct-2025.