Court Dismisses Claims of Negligent Hiring and Supervision, as well as Negligent Entrustment, Against Lyft

In the case of Henry v. Marcelin, No. 24-1891 (E.D. Pa. Sept. 25, 2024 Arteaga, J.), a judge in the Eastern District Federal Court of Pennsylvania granted the Defendant rideshare company’s Motion for Partial Judgment on the Pleadings in a personal injury case arising out of a motor vehicle collision.

According to the Opinion, the Plaintiff was a passenger that was involved in a motor vehicle accident that involved a rideshare vehicle.

Among her claims, the Plaintiff alleged that the Defendant, rideshare company (Lyft), was responsible on theories of negligent hiring and negligent entrustment. The Defendant rideshare company sought a partial judgment on the pleadings, arguing that the Plaintiff’s claim alleging negligent hiring, retention, training, and supervision, along with a claim for negligent entrustment, failed to state a claim within relief could be granted.

The court granted the rideshare defendant’s motion after finding that the Plaintiff failed to identify any past misconduct by the driver of the rideshare vehicle that would have put a reasonable employer on notice of an employee’s propensity for dangerous activities. The court also noted that there were no allegations offered by the Plaintiff to support an inference that the Defendant rideshare company knew that its driver was allegedly unqualified.

The court declined to recognize a genuine duty to investigate on the rideshare company’s part.

Accordingly, the court dismissed the Plaintiff’s claims of negligent hiring and related claims. 

The court also dismissed the claims for negligent entrustment. These claims were dismissed without prejudice and with leave granted to the Plaintiff to amend on the chance that the Plaintiff might be able to allege facts sufficient to state a claim upon which relief could be granted.

Anyone wishing to review a copy of this decision may click this LINK.  The Court's companion Order can be viewed HERE.


Source “Digest of Recent Opinions.” www.Law.com (Pennsylvania Law Weekly) (Oct. 11, 2024).