Lyft Lawsuit Over Rape by Fraudulent Driver Cleared To Move Forward, Involving Claims App Is a Defective Product

Court determined that Lyft must face product liability claims, even though the driver was working for the rideshare service under a false identity.

A federal judge has rejected a motion to dismiss a Lyft sexual assault lawsuit, determining that the rideshare company should face product liability claims brought by a woman who was raped by a driver working for the company after the app failed to detect a fake identity.

In March 2022, a woman identified only as Jane Doe in the complaint called for a Lyft to take her home, since she was too inebriated to drive. Her Lyft driver showed up with another person in the car. After driving her home, the two came into the apartment with her and sexually assaulted her while she was intoxicated and unconscious, and stole some of her possessions.

It turns out that the Lyft driver obtained access to the rideshare platform by using a fake identity, but actually had a criminal record and no driver’s license. However, the app failed to confirm the driver’s identity or identify differences between the driver’s photo and the false driver’s license submitted.

The driver was later identified as Michalia Williams. She had arrived with a man named Joshua Williams in the car with her, who also had a criminal record. As a result of the assault, Joshua Williams was sentenced to 32 months in prison for felony aggravated battery and Michalia Williams pled guilty to two counts of felony theft.

After the incident, Jane Doe filed a lawsuit against Lyft, indicating that the company failed to perform due diligence or conduct adequate checks to ensure the drivers they employ are actually the people they claim to be.

The complaint is one of a growing number of rideshare sexual assault lawsuits filed against Lyft and Uber over the past year, each raising similar allegations that the companies placed a desire for fast expansion and profits ahead of the safety of passengers relying on the app, by conducting inadequate driver background checks and failing to implement safety features that could have prevented drivers from raping or assaulting passengers.

After the lawsuit was filed, Lyft filed a motion in the U.S. District Court for the District of Kansas, seeking to have the case dismissed on a number of grounds. In addition, the company argued that the rideshare service shouldn’t be held responsible for the actions of its drivers.

In a memorandum and order (PDF) issued on November 1, U.S. District Judge John W. Brooms did agree to dismiss several claims brought under theories of vicarious liability, fraud and various consumer protection laws, but allowed the plaintiff’s product liability claims to proceed.

The Court found that the Lyft app is a software or algorithmic product, with sufficient similarities to a tangible product to subject it to product liability. In reaching his conclusions, Judge Brooms pointed to recent decisions in Uber sexual assault lawsuits, which are currently centralized before U.S. District Judge Charles Breyer in the Northern District of California as part of a multi-district litigation (MDL), as an example.

“The most persuasive precedent on this issue comes from the multi-district litigation decision regarding sexual assaults on the Uber platform,” Judge Brooms wrote. “Although finding that the Uber app was not a tangible product under the Restatement, Judge Breyer of the Northern District of California ruled that the design and distribution of the Uber app was ‘sufficiently analogous to the distribution and use of tangible personal property that it is appropriate to apply the rules of strict liability’.”

As a result of the order rejecting the motion to dismiss, pretrial proceedings will move forward in the case. According to a prior scheduling order (PDF) issued in July 2024, the parties are expected to complete all discovery by March 17, 2025 and submit a proposed pretrial order by March 31, 2025.

While the Lyft sexual assault lawsuits raise similar allegations to claims presented in Uber lawsuits, these cases have not been centralized as part of a federal multi-district litigation. Therefore, the lawsuit filed by Jane Doe and other plaintiffs are proceeding against Lyft individually in whichever district or state courts they were originally filed in.

The Uber sexual assault and harassment lawsuits are currently moving forward with coordinated discovery into common issues that impact all claims, and then it is expected that a small group of representative claims in the MDL will be selected for early bellwether trials.

While the outcome of any bellwether trials in the MDL will not be binding on other claims, average Uber sexual assault lawsuit payouts awarded by juries may influence later settlement agreements reached by either of the rideshare companies.