Summary
This Delaware Superior Court opinion grants Lyft, Inc.'s motion to dismiss Count II of the plaintiff's negligence complaint, ruling that the court lacks subject matter jurisdiction over the claim. The court determined that a valid arbitration agreement exists between the parties, containing a clear and unmistakable delegation clause that requires an arbitrator—not a court—to decide issues regarding the scope and applicability of the arbitration provision. Consequently, the negligence claims must be resolved through binding arbitration rather than litigation.
Topics
Practice areas
Questions Presented
- Whether the Superior Court of Delaware has subject‑matter jurisdiction over Count II of the complaint or must defer to the arbitration agreement.
- Whether the court may decide the arbitrability of the claims or must defer that question to an arbitrator.
Holdings
- The court lacks subject‑matter jurisdiction over Count II because the parties’ arbitration agreement delegates arbitrability to an arbitrator; therefore Count II is dismissed.
Key quotations
“The parties’ agreement provides in relevant part: “YOU AND LYFT MUTUALLY AGREE TO WAIVE OUR RESPECTIVE RIGHTS TO RESOLUTION OF DISPUTES IN A COURT OF LAW … AND AGREE TO RESOLVE ANY DISPUTE BY ARBITRATION… ALL DISPUTES AND CLAIMS BETWEEN US … SHALL BE EXCLUSIVELY RESOLVED BY BINDING ARBITRATION…"”
“A “clear and unmistakable intent to submit [substantive] arbitrability issues to an arbitrator exists if an arbitration clause: (1) ‘incorporates a set of arbitration rules that empower arbitrators to decide substantive arbitrability,’ and (2) ‘generally provides for arbitration of all disputes.’”
Factual background
On September 26, 2022, plaintiff Marcia Alexander was driving for Lyft when she was attacked by passenger Tylief Christopher. Alexander’s complaint asserted, among other things, a negligence claim against Lyft (Count II). The parties had previously entered into an arbitration agreement that required disputes to be resolved by arbitration, with limited exceptions that did not include Count II.
Procedural history
Plaintiff filed a complaint containing three counts. Lyft moved to dismiss Count II under Rule 12(b)(1) asserting lack of subject‑matter jurisdiction because the claim is subject to a binding arbitration agreement. The Superior Court considered the motion and issued an order granting it.