State of Nevada, Department of Employment Training and Rehabilitation ex. rel. Chagolla v. Lyft, Inc.

CourtDistrict Court, D. Nevada
DecidedFebruary 7, 2025
Docket3:23-cv-00442
StatusUnknown

This text of State of Nevada, Department of Employment Training and Rehabilitation ex. rel. Chagolla v. Lyft, Inc. (State of Nevada, Department of Employment Training and Rehabilitation ex. rel. Chagolla v. Lyft, Inc.) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Nevada, Department of Employment Training and Rehabilitation ex. rel. Chagolla v. Lyft, Inc., (D. Nev. 2025).

Opinion

1 2 3 4 5 6 7 8 9 10 11 12 13 UNITED STATES DISTRICT COURT 14 DISTRICT OF NEVADA 15 16 THE STATE OF NEVADA, DEPARTMENT Case No.: 3:23-cv-00442-ART-CLB 17 OF EMPLOYMENT TRAINING AND REHABILITATION, ex. rel. Chagolla ORDER GRANTING 18 Plaintiff, 19 JOINT AND UNOPPOSED MOTION TO STAY PROCEEDINGS v. 20 21 LYFT, INC., 22 Defendant. 23 Defendant Lyft, Inc. (“Defendant” or “Lyft”) and Relator Christina Michelle Chagolla 24 (“Relator”), collectively “the Parties”, by and through their respective counsel of record, 25 respectfully move the Court to issue a stay of the proceeding until Lyft’s Motion for 26 Reconsideration or, in the alternative, to Certify Questions to the Nevada Supreme Court (the 27 “Motion to Certify”) [Dkt Nos. 55, 56] is resolved. For the reasons stated in the accompanying 1 the Parties’ Motion. 2 MEMORANDUM OF POINTS AND AUTHORITIES 3 I. BACKGROUND 4 This is a one-count qui tam action brought by Relator against Lyft under the Nevada False 5 Claims Act (NFCA). See generally Am. Compl. The underlying facts of this case are set forth in 6 Relator’s Amended Complaint, Lyft’s Motion to Dismiss, Relator’s response thereto, and in Lyft’s 7 Motion to Certify. See Dkt Nos. 19, 22, 28, 31, 55, 56. For brevity and judicial economy, the Parties 8 will not repeat the facts except as necessary. See, e.g., United States v. State, No. 3:24-cv-00026- 9 MMD-CLB, 2024 U.S. Dist. LEXIS 80408, at *1-2 (D. Nev. May 1, 2024) (order granting joint 10 motion to stay discovery). 11 On December 13, 2023, Lyft moved to dismiss Relator’s Amended Complaint and her 12 NFCA claim, with prejudice, pursuant to Federal Rules of Civil Procedure 12(b)(6) and 9(b). See 13 generally Dkt. No. 22. In support, Lyft argued, among other reasons, that Relator failed to state an 14 actionable claim for relief under the NFCA’s “reverse false claims” provision for reasons of 15 substantive Nevada law. See id. at 8-16. Lyft’s Motion to Dismiss was dispositive of Relator’s 16 NFCA claim. See id.; see also Dkt No. 55. 17 On February 27, 2024, Lyft moved the Court to stay discovery in the matter pending the 18 Court’s resolution of Lyft’s Motion to Dismiss. Dkt No. 32. Relator did not oppose Lyft’s request 19 to stay discovery. See Dkt No. 33. 20 On March 12, 2024, the Court granted Lyft’s Motion to Stay Discovery. Dkt No. 34. The 21 Court granted Lyft’s requested stay “[i]n light of [Relator’s] non-opposition to a stay of 22 discovery[.]” Id. at 2. 23 On September 30, 2024, the Court denied Lyft’s Motion to Dismiss, lifting the stay 24 previously entered. See Dkt. No. 36. 25 On December 6, 2024, the Court issued an Order instructing the Parties to file a Joint Case 26 Management Report pursuant to Fed. R. Civ. P. 16. Dkt No. 47. 27 On January 21, 2025, the Parties filed a Stipulation to extend the time for them to file the 1 prepared and intended to file a motion to reconsider the Court’s September 30, 2024 Order or, in 2 the alternative, to certify the questions of Nevada law presented in Lyft’s Motion to Dismiss to the 3 Nevada Supreme Court. See id. Following Lyft’s filing of the Motion to Certify, the Parties 4 informed the Court that they intended to jointly request a stay of the proceedings, and the Court’s 5 Joint Case Management Report requirement, until the Motion to Certify is resolved. Id. ¶ 6. 6 On January 22, 2025, the Court granted the Parties’ Stipulation. Dkt No. 54. 7 On January 28, 2025, Lyft filed the Motion to Certify. Dkt Nos. 55, 56. In the Motion to 8 Certify, Lyft respectfully requested for the Court revisit, or reconsider, its September 30, 2024 9 Order denying Lyft’s Motion to Dismiss because the Court did not address the viability of Relator’s 10 NFCA claim in light of Lyft’s legal challenges raised to Relator’s claim under Nevada law. See Dkt 11 No. 55. Lyft argues that the Court erred by failing to decide the dispositive questions of Nevada 12 law raised in its Motion to Dismiss on which the Court should have dismissed Relator’s NFCA 13 claim. See id. As such, Lyft requested that the Court either dismiss Relator’s Amended Complaint 14 with prejudice or certify the questions of Nevada law presented in Lyft’s Motion to Dismiss to the 15 Nevada Supreme Court pursuant to Rule 5 of the Nevada Rules of Appellate Procedure. See id. 16 Relator has not yet responded to Lyft’s Motion to Certify, which is presently due on or 17 before March 4, 2025. Dkt No. 58. 18 The Parties now jointly move the Court to stay the proceedings in this matter. 19 II. ARGUMENT 20 The Parties respectfully request that the Court issue a stay of the proceeding until Lyft’s 21 Motion to Certify is resolved. While the Federal Rules of Civil Procedure do not expressly provide 22 a mechanism to stay actions, it is well-established that federal courts have broad discretionary 23 power under the Rules to control the sequencing of the proceedings before them. E.g. Gibson v. 24 MGM Resorts Int’l, No. 2:23-cv-00140-MMD-DJA, 2023 U.S. Dist. LEXIS 118890, at *8 (D. Nev. 25 July 11, 2023). “The guiding premise of the Rules is that the Rules ‘should be construed and 26 administered to secure the just, speedy, and inexpensive determination of every action.’” 27 Czerniewski v. Keppel, No. 2:18-cv-02078-KJD-VCF, 2020 U.S. Dist. LEXIS 167975, at *2 (D. 1 mandated that trial courts [] resolve civil matters fairly but without undue cost.” Id. (citing Brown 2 Shoe Co. v. United States, 370 U.S. 294, 306 (1962)). In keeping with the Rules’ tenets of cost- 3 effective, efficient litigation, courts in this District issue stays of proceedings, including stays of 4 discovery, under circumstances where there is a pending motion that is potentially dispositive of an 5 action before the court. See id. at 3 (citing TradeBay, LLC v. Ebay, Inc., 278 F.R.D. 597, 600 (D. 6 Nev. 2011)). 7 To determine whether a stay is appropriate, courts in this District generally consider (1) 8 whether the pending motion is potentially dispositive of the entire case; and (2) whether the 9 potentially dispositive motion can be decided without additional discovery. Baham v. Graham, No. 10 2:23-cv-00822-ART-BNW, 2023 U.S. Dist. LEXIS 206121, at *2-3 (D. Nev. Nov. 17, 2023). This 11 approach “requires the Court to take a ‘preliminary peek’ at the merits of the pending dispositive 12 motion.” Id. at *3. However, this requirement does not appear to be universally applied by all courts 13 in the District. State, 2024 U.S. Dist. LEXIS 80408 at *5-6 (collecting cases); accord Gibson, 2023 14 U.S. Dist. LEXIS 118890 at *9 (“[T]he preliminary peek test can sometimes be problematic 15 because it can be inaccurate and inefficient.”) (citation omitted). Courts in this District that eschew 16 performing a “preliminary peek” of the pending dispositive motion employ a somewhat similar 17 analysis to guide whether a stay of the proceedings should be issued. See Gibson, 2023 U.S. Dist. 18 LEXIS 118890 at *9. Under this alternative approach, the Court considers “(1) whether the 19 dispositive motion can be decided without further discovery, and (2) whether good cause exists to 20 stay discovery.” Id. Good cause may be established through a showing that a continuation of the 21 proceeding during the motion’s pendency would cause an “undue burden or expense.” Id. at *9-10. 22 Lyft’s Motion to Certify meets either standard for a stay to issue until the motion is resolved.

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Related

Brown Shoe Co. v. United States
370 U.S. 294 (Supreme Court, 1962)
Tradebay, LLC v. eBay, Inc.
278 F.R.D. 597 (D. Nevada, 2011)

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Bluebook (online)
State of Nevada, Department of Employment Training and Rehabilitation ex. rel. Chagolla v. Lyft, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-nevada-department-of-employment-training-and-rehabilitation-ex-nvd-2025.