Freyer v. Lyft, Inc., 2021 WL 5879188, --- S.W.3d --- (Tex. App. --- Dallas, Dec. 13, 2021)

Court of Appeals affirms summary judgment for rideshare company based, in part, on Transportation Network Company statute.

The trial court granted summary judgment in favor of Lyft, Inc. in a personal injury action where the plaintiff sustained injuries while riding in a car driven by one of Lyft’s independent drivers. The driver had an emergency medical episode resulting in an accident. 

The Dallas Court of Appeals affirmed, finding that Lyft complied with the applicable provisions of the Texas Transportation Network Company (TNC) statute. Under the TNC statute, if the TNC complies with certain provisions, TNC drivers are deemed independent contractors and the TNC cannot be held vicariously liable for the drivers’ negligence. Based on rules of statutory construction, the Texas Court of Appeals found that a TNC is not required to verify a driver’s eligibility before a driver logs in each time. 

The court also found that, regardless of whether the TNC statute abrogates common law negligence claims, the plaintiff failed to raise genuine issues of material fact as to her direct negligence claims of negligent hiring and retention of an independent contractor as well as negligent undertaking. 

This decision is among the first to address the applicability of a TNC statute that limits liability, and it highlights the fact-intensive analysis required in defending rideshare liability claims.


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