Marez v. Lyft, Inc.Annotate this Case
Gaurano, driving home from a day of working at the convention center in a vehicle rented through Lyft’s “Express Drive program,” struck the plaintiffs’ vehicles and caused significant injuries. The trial court granted Lyft summary judgment.
The court of appeal affirmed. Gaurano was not acting within the scope of his employment with Lyft at the time of the accident. The court rejected arguments that Lyft required drivers to drive the rental, that driving the rental was “ ‘incident to [Gaurano’s] duties’ ” because he had to be in the rental to pick up rides, and that Lyft’s encouragement of personal driving in the rental made accidents more likely. As a matter of law, Gaurano had substantially deviated from any duties he performed for Lyft at the time of the accident. Gaurano had not worked for Lyft on that day and had no intention of doing so. The potential for Gaurano to log onto the Lyft platform, alone, is insufficient to bring all of his personal driving within the scope of his Lyft employment. Gaurano’s conduct was not foreseeable and Lyft derived no benefit from it. The court also rejected an argument that the trial court abused its discretion in limiting the scope of a person most qualified (PMQ) deposition.