In a recent opinion, a California court refused to hold a ridesharing company liable for an accident caused by one of its drivers. The driver was using a car made available to him through the ridesharing company when he caused a California car accident resulting in injuries to two other motorists. The injured motorists filed a lawsuit against the ridesharing company, as well as the driver, arguing that the ridesharing company should be held liable for the driver’s actions while using a car provided through the driver’s employment. The ridesharing company denied legal responsibility, arguing that the driver was engaged in purely personal activity at the time of the accident.
The main issue, in this case, was whether the driver was acting within the scope of their employment when the accident occurred. An employer may be held liable for injuries wrongfully caused by an employee where the injured party filing the lawsuit proves that the person who caused the injury was acting “within the scope” of their employment. Conversely, an employer is not liable where the employee’s activity was “purely personal.
California uses two tests to determine whether an employee was acting within the scope of their employment at the time of an accident. The first is the Purton test, which considers whether the employee’s activity was undertaken with the employer’s permission, and whether it was of some benefit to the employer or typical within the context of employment. The second test is the Halliburton test, which considers whether the activity was required or incident to the employee’s duties, or whether the employee’s misconduct was reasonably foreseeable by the employer.
In this instance, the court refused to hold the ridesharing company liable for the driver’s actions because the driver was engaged in purely personal pursuits at the time of the accident. The driver who caused the accident was using a car provided through his employment with the company. However, he was not driving for the company at the time of the accident. Instead, he was on his way from a different job when he hit the plaintiffs, and he had no plans to drive for the ridesharing company that day. The court found that the connection between the driver’s actions and his employment with the company was not sufficient to justify holding the company liable. In ruling this way, the court explicitly rejected a broad rule that would hold ridesharing companies responsible for accidents occurring anytime an employee is driving an approved vehicle.
The court also pointed out that this situation differed from previous cases where employers have been held liable. First, the driver was not working for the ridesharing company at the time of the accident, but instead was engaged in activity of a completely personal nature. Second, the driver was not involved in risky conduct that was facilitated by the company. For example, courts have held employers liable where the employee caused an accident while driving under the influence after leaving a company gathering. However, merely providing the driver with the car and the option to drive it for personal, as well as business activity, is not sufficient to hold the employer liable for the employee’s conduct. As a result, the plaintiff’s case was dismissed by the court.
Have You Been Injured in an Accident Caused by an Uber or Lyft Driver?
If you or someone you know has been injured in a Los Angeles car accident with a driver from a ridesharing company, such as Uber or Lyft, you may be entitled to compensation. The Sharifi Firm, APC, has a long history of successfully representing accident victims across the state of California. Our experienced attorneys understand the complex issues these cases present, and have the knowledge and skills to get you a positive outcome. Contact our office at 866-422-7222 for a free consultation.