Bonhomme v. Uber Technologies, Inc.

District Court, N.D. California·Decided June 24, 2025·No. 4:24-cv-07998·Unknown

Opinion

DESMOND BONHOMME, et al., Case No. 24-cv-07998-JST

Plaintiffs, ORDER GRANTING MOTION TO v. COMPEL ARBITRATION AND STAY PROCEEDINGS Re: ECF No. 12 Defendant.

Before the Court is Defendant Uber Technologies, Inc.’s motion to compel arbitration and stay proceedings. ECF No. 12. The Court will grant the motion. Plaintiffs Desmond Bonhomme and Daniel Tyler bring this putative class action against Uber for alleged violations of New York City Administrative Code, Section 20-1501, et seq. They contend that Uber violated the Code’s requirement to “‘disclose to [a food delivery] worker . . . the address where the food, beverage, or other goods must be picked up’” by instead offering drivers only a “zoomed-out map, rather than . . . actual addresses.” ECF No. 1-1 ¶¶ 2–3 (quoting N.Y.C. Admin. Code § 20-1521). Uber has now moved to compel arbitration of Plaintiffs’ claims. The parties do not dispute that they entered into Uber’s Platform Access Agreement (PAA), which contains an arbitration clause. See ECF No. 17 at 8 (Plaintiffs acknowledging that “they have an agreement to arbitrate with Defendant”). Plaintiffs contend, however, that the arbitration clause is unconscionable and therefore unenforceable. The Federal Arbitration Act (“FAA”) applies to written contracts “evidencing a transaction involving commerce.” 9 U.S.C. § 2. Under the FAA, arbitration agreements “shall be valid, irrevocable, and enforceable, save upon such grounds as exist at law or in equity for the revocation of any contract.” 9 U.S.C. § 2. This provision reflects “both a liberal federal policy favoring arbitration, and the fundamental principle that arbitration is a matter of contract.” AT&T Mobility LLC v. Concepcion, 563 U.S. 333, 339 (2011) (quotation marks and citations omitted). On a motion to compel arbitration, the Court’s role under the FAA is “limited to determining (1) whether a valid agreement to arbitrate exists and, if it does (2) whether the agreement encompasses the dispute at issue.” Chiron Corp. v. Ortho Diagnostic Sys., Inc., 207 F.3d 1126, 1130 (9th Cir. 2000). Section 2 of the FAA provides that an arbitration agreement “shall be valid, irrevocable, and enforceable, save upon such grounds as exists at law or in equity for the revocation of any contract.” 9 U.S.C. § 2. “The final clause of § 2, generally referred to as the savings clause, permits agreements to arbitrate to be invalidated by generally applicable contract defenses, such as fraud, duress, or unconscionability, but not by defenses that apply only to arbitration or that derive their meaning from the fact that an agreement to arbitrate is at issue.” Lim v. TForce Logistics, LLC, 8 F.4th 992, 999 (9th Cir. 2021) (quoting Poublon v. C.H. Robinson Co., 846 F.3d 1251, 1259 (9th Cir. 2017)). “[T]he party opposing arbitration bears the burden of proving any defense, such as unconscionability.” Id. On a motion to compel arbitration, “courts rely on the summary judgment standard of Rule 56 of the Federal Rules of Civil Procedure.” Hansen v. LMB Mortg. Servs., Inc., 1 F.4th 667, 670 (9th Cir. 2021). “Courts may consider evidence outside of the pleadings, such as declarations and other documents filed with the court.” Burger v. Northrop Grumman Sys. Corp., No. 21-cv- 06761-ABM-RWX, 2021 WL 8322270, at *4 (C.D. Cal. Oct. 27, 2021). Under Rule 56, “[a]n affidavit or declaration used to support or oppose a motion must be made on personal knowledge, set out facts that would be admissible in evidence, and show that the affiant or declaration is competent to testify on the matters stated.” Fed. R. Civ. P. 56(c)(4). comply therewith is not in issue, the court shall make an order directing the parties to proceed to arbitration in accordance with the terms of the agreement.” 9 U.S.C. § 4. Where the claims alleged in a complaint are subject to arbitration, the Court may stay the action pending arbitration. 9 U.S.C. § 3. When deciding whether a valid arbitration agreement exists, federal courts “apply ordinary state-law principles that govern the formation of contracts.” First Options of Chi., Inc. v. Kaplan, 514 U.S. 938, 944 (1995). Although the parties dispute whether California or New York law applies, Plaintiffs note—and Uber does not dispute—that the two states’ laws are consistent on the question of contract formation. ECF No. 17 at 15 (citing Prince of Peace Enters., Inc. v. Top Quality Food Mkt., LLC, 760 F. Supp. 2d 384, 397 (S.D.N.Y. Mar. 14, 2011) (“[T]he law regarding the formation of an enforceable agreement is the same in both jurisdictions [New York and California]”)). The Court therefore need not make a choice-of-law determination. See Nguyen v. Barnes & Noble Inc., 763 F.3d 1171, 1175 (9th Cir. 2014) (declining to decide whether California or New York law applied because the laws of both states “dictate the same outcome”). Arbitration agreements may be invalidated by “generally applicable contract defenses, such as fraud, duress, or unconscionability.” Rent-A-Center, W., Inc. v. Jackson, 561 U.S. 63, 68 (2010) (quoting Doctor’s Assocs., Inc. v. Casarotto, 517 U.S. 681, 687 (1996)). With respect to unconscionability, “[g]enerally, there must be a showing that . . . a contract is both procedurally and substantively unconscionable in order to preclude enforcement.” Saizhang Guan v. Uber Techs., Inc., 236 F. Supp. 3d 711, 730 (E.D.N.Y. 2017) (internal quotation marks omitted); Performance Team Freight Sys., Inc. v. Aleman, 241 Cal. App. 4th 1233, 1247 (2015) (“Substantive unconscionability alone does not render a contract unenforceable, however. Procedural unconscionability must also be shown.”). But, at least under New York law, “there have been exceptional cases where a provision of the contract is so outrageous as to warrant holding it unenforceable on the ground of substantive unconscionability alone.” Id. (quoting Ragone v. Atl. Video at Manhattan Ctr., 595 F.3d 115, 121 (2d Cir. 2010)).1 A. Delegation Clause “[P]arties can agree to arbitrate ‘gateway’ questions of ‘arbitrability,’ such as whether the parties have agreed to arbitrate or whether their agreement covers a particular controversy.” Rent- A-Center, W., Inc. v. Jackson, 561 U.S. 63, 68–69 (2010) (quoting Howsam v. Dean Witter Reynolds, Inc., 537 U

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