Singh v. Uber Technologies, Inc., No. 17-1397 (3d Cir. 2019)Annotate this Case
The Federal Arbitration Act (FAA), 9 U.S.C. 1–16, places certain arbitration agreements on equal footing with all other contracts, requiring courts to enforce such agreements according to their terms. Section 2 provides that the FAA covers “a written provision in any maritime transaction or a contract evidencing a transaction involving commerce,” but section 1 states that “nothing” in the FAA “shall apply to contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce.” Singh brought this putative class action on behalf of New Jersey Uber drivers, alleging that Uber misclassified them as independent contractors rather than employees, which resulted in their being deprived of overtime compensation and incurring business expenses for Uber's benefit. Singh opposed a motion to compel arbitration, arguing that, to the extent that he had an agreement with Uber, it fell within the “any other class of workers” portion of section 1. The court dismissed, concluding that clause only extends to transportation workers who transport goods. The Third Circuit disagreed, citing its “longstanding precedent,” to hold that the residual clause of section 1 may extend to a class of transportation workers who transport passengers if they are engaged in interstate commerce or in work so closely related thereto as to be in practical effect part of it. The court remanded for resolution of the engaged-in-interstate-commerce inquiry.