United States: Lyft Was Not Liable For Accident Involving One Of Its Drivers

While driving a car rented through Lyft's "Express Drive Program," Jonathan Guarano struck the plaintiffs and caused significant injuries. Plaintiffs sued Lyft under the doctrine of respondeat superior, but the trial court granted summary judgment to Lyft on the ground that at the time of the accident, Guarano was not acting within the course and scope of his employment. The Court of Appeal affirmed summary judgment for Lyft, holding that at the time of the accident, Guarano was returning home from working at a gaming conference in San Francisco, which was not within the course and scope of his employment for Lyft. See also Alaniz v. Sun Pac. Shippers, L.P., 2020 WL 2029279 (Cal. Ct. App. 2020) (trial court erred by failing to instruct jury about the Privette/Hooker doctrine relating to a landowner's responsibility to employees of an independent contractor, despite defendants' failure to request same).