According to the Opinion, Lyft filed a Motion to Dismiss a lawsuit brought by a Lyft driver who claimed that he was entitled to uninsured motorist coverage following a motor vehicle accident.
The court determined that the terms of service agreement and a promise in a driver guidebook was a binding contract between Lyft and one of its drivers who was the Plaintiff at issue in this case.
According to the Opinion, the guidebook promised Lyft drivers that “‘we’ve got you with our $1million insurance policy,’” and that “‘there are four coverages included in our insurance policy.’” including underinsured/uninsured (UM/UIM motorist coverage).
In the Opinion, it was indicated that the Plaintiff claimed he was denied coverage by the UM carrier after he was in an accident with an uninsured driver. Coverage was denied even though Lyft previously allegedly informed the Plaintiff that he and his car would be insured.
According to the Opinion, prior to the accident, Lyft had waived the UM/UIM coverage for its Pennsylvania drivers, without informing them.
The Plaintiff filed suit against Lyst seeking entitlement to uninsured motorist benefits, as well as claims of breach of contract, fraudulent misrepresentation, violations of Pennsylvania’s Unfair Trade Practices and Consumer Protection Law, and negligent misrepresentation.
In his Complaint, the Plaintiff additionally sought a declaratory judgment that Lyft had a duty to provide him with up to $1 million dollars in uninsured motorist coverage.
The breach of contract claim revolved around the parties’ alleged agreement and the driver guidebook, which Lyft argued was not part of its contract with the Plaintiff.
The court concluded that the agreement’s interpretation, including whether it incorporated references to the guidebook’s UM/UIM coverage promise, was governed by California law as that was where Lyft maintained its principal place of business.
The Plaintiff claimed that the driver’s agreement and the guidebook, when considered together, constituted his contract with Lyft that he relied upon. The Plaintiff more specifically asserted that he relied upon the provision and the guidebook that “in the event of an accident…our UM/UIM coverage will apply up to $1million per accident.”
Lyft attempted to argue that this representation was barred as a matter of law by the parol evidence rule.
The court found that the parol evidence rule did not serve to exclude evidence that is offered to explain any ambiguity or to otherwise assist in the interpretation of the terms of an alleged agreement.
The court noted that, where it is decided by the court that the language of a contract is ambiguous or fairly susceptible of more than one interpretation, extrinsic evidence relevant to prove any of the possible meanings is admissible to assist in the determination of the term of the contract.
The court noted that, in this matter, the agreement contained two provisions that indicated that the guidebooks promised to provide Lyft drivers with uninsured and underinsured motorist coverage was part of the contractual relationship between the drivers and the company.
Overall, the court found that the Plaintiff’s allegations that Lyft breached the guidebook’s clear promise of UM/UIM coverage was sufficient to plausibly state a claim for breach of contract.
The court also rejected arguments by Lyft that a disclaimer in the guidebook prevented the guidebook from being interpreted as it was being interpreted by the court.
In the end, the federal court judge from the Eastern District denied Lyft’s Motion to Dismiss the lawsuit brought by this Lyft driver who claims that he is entitled to uninsured motorist coverage under a Lyft Insurance policy.
Anyone wishing to review a copy of this decision may click this LINK. The Court's companion Order can be viewed HERE.
I send thanks to Attorney Jimmy Kunnell of the Feasterville-Trevose, PA law firm of Kunnell Law for bringing this case to my attention.
See also: Article “Federal Judge Sized With Lyft Driver In Contractual Dispute Over $1M Uninsured Motorist Coverage” By Riley Brennan of The Legal Intelligencer (Sept. 13, 2024).
Overall, the court found that the Plaintiff’s allegations that Lyft breached the guidebook’s clear promise of UM/UIM coverage was sufficient to plausibly state a claim for breach of contract.
The court also rejected arguments by Lyft that a disclaimer in the guidebook prevented the guidebook from being interpreted as it was being interpreted by the court.
In the end, the federal court judge from the Eastern District denied Lyft’s Motion to Dismiss the lawsuit brought by this Lyft driver who claims that he is entitled to uninsured motorist coverage under a Lyft Insurance policy.
Anyone wishing to review a copy of this decision may click this LINK. The Court's companion Order can be viewed HERE.
I send thanks to Attorney Jimmy Kunnell of the Feasterville-Trevose, PA law firm of Kunnell Law for bringing this case to my attention.
See also: Article “Federal Judge Sized With Lyft Driver In Contractual Dispute Over $1M Uninsured Motorist Coverage” By Riley Brennan of The Legal Intelligencer (Sept. 13, 2024).
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