Lyft
ATLANTA — Lyft doesn’t have to defend itself against a lawsuit by a man who was severely beaten by a driver after an argument over where he was going, a Georgia appeals court ruled.
The ridesharing service couldn’t have anticipated Roy Sallie would respond violently to the passenger’s criticism of his driving even though Sallie had a prior driving offense on his record and two passengers had left him 1-star reviews and accused him of being intoxicated.
“A prior speeding ticket is not evidence of an incident similar to the violent behavior that caused the injuries at issue,” the Georgia Court of Appeals ruled in an Oct. 27 decision by Judge Sara Doyle.
Williams Evans was trying to get to the rental-car facility at the Atlanta airport in 2020 when he got into Sallie’s car. Sallie drove to both the north and south airport terminals and then to a “restricted-access offsite parking area” before Williams started using his own phone to guide the driver. The argument escalated until Sallie stopped and ordered Williams out of the car. He obliged and removed his luggage from the trunk, after which Sallie got out of the car and beat him unconscious.
Lyft kicked Sallie off the platform after the incident, but Williams sued, arguing the company was on notice he was a bad driver. He’d been ticketed for driving 94 mph in a 55 mph zone in Virginia, a charge he pled down to improper driving. Lyft’s corporate representative testified Sallie would have been barred from the platform if he’d been convicted of the higher offense of reckless driving.
The company also had two reports from passengers, including one who said, “I felt like the driver was on something.” Lyft has a zero-tolerance drug and alcohol policy, but took no action on the passenger reviews.
The trial judge dismissed the case against Lyft and entered a $12.1 million judgment against Sallie, who didn’t appear. The appeals court affirmed the dismissal, citing a string of its own decisions refusing to hold employers liable for crimes by their employees despite knowledge of other unrelated convictions or drug and alcohol problems. In this case, the court said, Sallie was an independent contractor, also eliminating liability for negligent hiring, training or supervision.
“There is no evidence that Lyft knew of Sallie’s propensity for aggression and violence or that it was reasonably foreseeable that his apparent issues with drugs and/or alcohol would result in the injuries sustained by Evans,” the court concluded, citing a string of appellate decisions where employers weren’t held liable for crimes committed by their employees despite knowledge of other, unrelated convictions or drug and alcohol problems.
