Products Liability Law Reporter

A federal district court held that an alleged sexual assault victim’s products liability claim against Lyft, Inc., was not timely filed.

Doe allegedly was sexually assaulted while getting a ride through Lyft. She sued Lyft, Inc., alleging various claims—including negligence and gross negligence—and seeking punitive damages. Lyft removed the suit to federal court and moved to dismiss. The district court dismissed some of the plaintiff’s claims without prejudice. She then filed a second amended complaint, asserting strict products liability and other claims. The plaintiff asserted that the person who allegedly assaulted her was not an authorized Lyft driver but someone who was using a Lyft driver’s account. The plaintiff added that the defendant failed to change its application or algorithm to prevent or reduce the incidence of sexual assault. The defendant moved to dismiss.

Granting the motion regarding the plaintiff’s strict liability claim, the court found that the plaintiff brought the claim after the relevant two-year limitations period had expired. The court also rejected the plaintiff’s assertion that the products liability claim related back to her original complaint because it was based on the same core of operative facts. Although the defendant had notice of the plaintiff’s sexual assault allegation, the court said, this did not provide the defendant with notice that the plaintiff would pursue a legal theory based on the defective design of the Lyft application and algorithm. Nowhere in the plaintiff’s original complaint did she mention a possible design defect or issue with the Lyft application and algorithm, the court found.

Consequently, the court granted the defendant’s motion to strike the plaintiff’s products liability claim.

Citation: Doe v. Lyft, 2024 WL 4479912 (E.D. Pa. Oct. 10, 2024).