Bruster v. Uber Technologies Inc.

188 F. Supp. 3d 658, 2016 U.S. Dist. LEXIS 67523, 2016 WL 2962403
CourtDistrict Court, N.D. Ohio
DecidedMay 23, 2016
DocketCASE NO. 15-CV-2653
StatusPublished
Cited by8 cases

This text of 188 F. Supp. 3d 658 (Bruster v. Uber Technologies Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bruster v. Uber Technologies Inc., 188 F. Supp. 3d 658, 2016 U.S. Dist. LEXIS 67523, 2016 WL 2962403 (N.D. Ohio 2016).

Opinion

OPINION & ORDER

JAMES S. GWIN, UNITED STATES DISTRICT JUDGE

Plaintiff Ladon Bruster brings Ohio wage and labor law claims against Defendants Uber Technologies Inc. and its subsidiary, Rasier, LLC (collectively, “Uber”).1 Defendants move to dismiss this case and compel arbitration under the terms of the parties’ June 2014 Technology Services Agreement (the “June 2014 Agreement”).2 For the following reasons, this Court GRANTS Defendants’ motion to dismiss and compel arbitration.

I. Background

On July 30, 2014, Plaintiff Bruster activated his Uber account and began work as an Uber driver.3 In order to sign up as an Uber driver, Plaintiff had to accept Uber’s June 21, 2014, Agreement. The Agreement appeared on Plaintiffs phone through Defendants’ Uber App. Plaintiff received as much time as he wished to review the Agreement before deciding whether to electronically accept or reject the Agreement.

On July 31, 2014, Plaintiff accepted the June 2014 Agreement. The Agreement contained the prominent class action waiver, arbitration and delegation provisions.4

Although the Agreement had given the Plaintiff the ability to opt out of the arbitration provision, Plaintiff Bruster did not [661]*661opt out of the June 2014 Agreement’s arbitration provision within 30 days of acceptance.

On November 27, 2015, Defendants deactivated Plaintiffs Uber account because of “continued unsatisfactory customer experiences.”5 In this lawsuit, the Plaintiff complains of Uber’s treatment during the period before Uber’s November 27, 2015, account termination.

After Uber ended Plaintiffs Uber account, on December 11, 2015, Uber rolled [662]*662out a revised Agreement to its drivers. Despite Uber having deactivated Plaintiffs account, Plaintiff “accepted” the December 11, 2015 Agreement by tapping the “YES, I AGREE” button on Plaintiffs phone.6 On December 16, 2015, Plaintiff sent a purported opt-out notice to Defendants.

On December 21, 2015, Plaintiff Bruster filed this lawsuit. On March 25, 2016, Defendants moved to dismiss the case and compel arbitration. Defendants say that the June 2014 Agreement’s delegation provision requires an arbitrator—not this Court—to determine the enforcéability of the arbitration provision. Uber also says that the June 2014 Agreement gave the arbitrator, but not this Court, authority to address the merits of Plaintiffs claims. Defendants also say that the arbitration provision is itself valid and therefore requires arbitration of Plaintiffs claims.

With his opposition, Plaintiff says that he opted out of the June 2014 arbitration and delegation provisions by accepting the December 11, 2015 Agreement and sending an opt-out notice. Plaintiff also says that the June 2014 Agreement arbitration provisions are unconscionable and therefore unenforceable.

II. Legal Standard

The Federal Arbitration Act, 9 U.S.C. § 1 et seq., (“the FAA”) governs arbitration and delegation disputes. Section 4 authorizes a' district court to compel parties to arbitrate if the district court finds that the parties entered a valid and enforceable arbitration agreement that covers the dispute.7

Section 2 of the FAA says that arbitration provisions “shall be valid, irrevocable, and enforceable, save upon such grounds as exist at law or in equity for the revocation of any contract.”

District courts consider challenges to the validity of an arbitration provision independently from the rest of an agreement.8

District “[c]ourts are to examine the language of the contract in light of the strong federal policy in favor of arbitration. Likewise, any ambiguities in the contract or doubts as to the parties’ intentions should be resolved in favor of arbitration.”9

Parties may delegate gateway issues of arbitrability to the arbitrator.10 A discrete agreement to submit gateway ar-bitrability questions to the arbitrator is treated as “an additional, antecedent agreement the party seeking arbitration asks the federal court to enforce!.]”11 However, the presumption in favor of arbitration does not apply to delegation clauses. “Unless the parties clearly and unmistakably provide otherwise, the question of whether the parties agreed to arbitrate is to be decided by the court, not the arbitrator.”12

[663]*663The FAA preempts state arbitration laws.13 However, state contract.law applies to determine the validity of the arbitration provision.14

District courts sitting in diversity apply the choice of law rules of the forum state.15 “Absent an effective choice of law provision, Ohio courts apply the law of the state with the most significant relationship to the contract.”16

III. Discussion

Plaintiff is Bound by the June 2014 Agreement

The parties entered into a valid agreement when Plaintiff accepted the June 2014 agreement and started driving using the Uber app. Plaintiff could have opted out of the arbitration and delegation provisions by August 80, 2014, but did not. Therefore, the arbitration and .delegation provisions applied from July 31, 2014—the day Plaintiff accepted the' June 2014 Agreement—onward.17

Plaintiffs purported “acceptance” of the December 2015 agreement and purported “opt-out” of the December 2015 arbitration and delegation provisions are not valid. First, the December 2015 Agreement is not an enforceable agreement between the parties.18 Uber deactivated Plaintiffs account in November 2015, several weeks before Plaintiff attempted to accept the December 2015 agreement. With its deactivation of Plaintiffs account, Uber withdrew from an ongoing contractual relation with Plaintiff.

The appearance of the December 2015 Agreement on Plaintiffs phone is insufficient to show that Defendants were making an offer to Plaintiff. Defendants had already deactivated Plaintiffs account, and there is no indication that Defendant's' intended the December 2015 agreement to reach Plaintiff. Absent an offer, there is no contract formation.

Furthermore,' theré was no consideration to support Plaintiffs purported acceptance. Because Defendants deactivated Plaintiffs account, Plaintiff could not connect with potential passengers through the Uber App at the time Plaintiff tried to accept the December 2015 Agreement and could not get any business through Uber.

Because there was no new agreement to replace the June 2014 Agreement, the arbitration and delegation provisions of the June 2014 Agreement apply.

The June 2014 Agreement’s Delegation Provision is Valid and Enforceable

The parties agreed to submit arbi-trability questions to an arbitrator, not to the Court. The June 2014 Agreement says:

.. .this Arbitration Provision is intended to apply to the resolution of disputes [664]

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Related

Smythe v. Uber Technologies, Inc.
California Court of Appeal, 2018
Smythe v. Uber Techs., Inc.
233 Cal. Rptr. 3d 895 (California Court of Appeals, 5th District, 2018)
Rimel v. Uber Technologies, Inc.
246 F. Supp. 3d 1317 (M.D. Florida, 2017)
Kai Peng v. Uber Technologies, Inc.
237 F. Supp. 3d 36 (E.D. New York, 2017)
Saizhang Guan v. Uber Technologies, Inc.
236 F. Supp. 3d 711 (E.D. New York, 2017)
Singh v. Uber Technologies Inc.
235 F. Supp. 3d 656 (D. New Jersey, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
188 F. Supp. 3d 658, 2016 U.S. Dist. LEXIS 67523, 2016 WL 2962403, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bruster-v-uber-technologies-inc-ohnd-2016.