Aykut Pilak v. Uber Technologies

Summary

The United States District Court for the Eastern District of Missouri grants Uber Technologies’s motion to compel arbitration in Aykut Pilak’s discrimination and compensation dispute. The court holds that Pilak accepted agreements containing arbitration and delegation provisions, and that his constitutional and contract-validity challenges must be decided by the arbitrator. The court also rejects his argument that Uber drivers fall within the Federal Arbitration Act’s transportation-worker exception and stays the case pending arbitration.

Holdings

1. Where an arbitration agreement contains a valid, unchallenged delegation provision, the court must refer arbitrability questions and antecedent challenges to the validity of the underlying arbitration agreement to the arbitrator.
2. Uber rideshare drivers, considered as a nationwide class of workers, are not engaged in interstate commerce within the meaning of 9 U.S.C. § 1 merely because some drivers transport passengers across state lines or to airports and train stations.
3. Because Pilak entered binding arbitration agreements containing provisions encompassing his claims, and he failed to establish the FAA transportation-worker exception, Uber was entitled to an order compelling arbitration and a stay of the action.

Questions Presented

1. Whether the court could decide Pilak's constitutional and contract-validity challenges when the agreements contained an unchallenged delegation provision.
2. Whether Uber drivers are a class of workers engaged in interstate commerce and therefore exempt from the Federal Arbitration Act's transportation-worker exception.
3. Whether Uber's motion to compel arbitration should be granted and the action stayed.

Disposition

other