## Facts

- Lokeshwaran Narayanasamy used the Uber smartphone application to request a ride from T.F. Green Airport to his hotel.
- Claudette Issa, a driver registered on Uber’s platform, accepted the request and picked him up.
- During the trip, Issa’s vehicle collided with a disabled vehicle owned by Balise T, LLC that had been left by the roadside after breaking down.
- Narayanasamy and Issa were injured.
- Narayanasamy, along with his wife Savitry Krishnamurthy and their minor child, sued Issa, Balise, Rasier, LLC and Uber Technologies, Inc. (collectively, Uber), and unidentified John/Jane Doe defendants.
- As to Uber, plaintiffs sought to hold Uber liable for Issa’s alleged negligence under respondeat superior (vicarious liability).
- The summary-judgment record included evidence about Uber’s business model and platform practices, including that Uber set fares, controlled branding and marketing, conducted background checks, set driver quality and conduct standards, managed rider-driver communications and dispute handling through the app, and offered certain insurance benefits.
- Rhode Island classified Uber as a “transportation network company,” and state law treated transportation network company drivers as independent contractors.
- Issa’s written agreement with Uber also stated she was an independent contractor.
- Balise filed crossclaims against Issa and Uber seeking contribution and indemnification and alleging, among other things, negligent hiring, training, and supervision; other crossclaims were also filed among the defendants.
- Uber moved for summary judgment, arguing Issa was not Uber’s agent, servant, or employee as a matter of law, and Uber separately moved to strike and/or objected to portions of Balise’s summary-judgment materials.

## Issues

1. Whether Uber was entitled to summary judgment on the ground that Issa was not Uber’s agent, servant, or employee as a matter of law, so Uber could not be held vicariously liable under respondeat superior.
2. Whether the court should strike or disregard challenged portions of Balise’s factual submissions at the summary-judgment stage.

## Decision

- The court denied Uber’s motion for summary judgment.
- The court held that, on this record, there were genuine disputes of material fact about the nature of the relationship between Uber and Issa, making summary judgment inappropriate on respondeat superior.
- The court denied Uber’s motion to strike, concluding that the record contained enough disputed, relevant evidence to proceed and that most evidentiary objections were better addressed at trial.

## Legal Principles

- Summary judgment is appropriate only when there is no genuine dispute of material fact and the movant is entitled to judgment as a matter of law; the court must view the record and reasonable inferences in the light most favorable to the nonmovant.
- Under Rhode Island respondeat superior doctrine, whether a worker is an employee/agent or an independent contractor depends on the actual relationship, with emphasis on the principal’s right to control the manner and means of the work.
- Contractual labels (including “independent contractor” provisions) and statutory classifications may be considered, but they do not automatically resolve the agency/employment question when the record contains competing evidence about control and the parties’ real-world arrangement.
- Where evidence of control and operational practices could support different findings about agency or employment, the issue is typically for the jury rather than resolution as a matter of law at summary judgment.
- A district court may decline to resolve many evidentiary disputes through a motion to strike at the summary-judgment stage when those disputes are more appropriately handled through trial rulings.

## Conclusion

Narayanasamy v. Issa denied Uber’s attempt to exit the case at summary judgment because the record contained disputed evidence about Uber’s control and platform-based oversight that could allow a jury to find an agency or employment relationship for respondeat superior purposes, despite Rhode Island’s transportation-network classification and the driver agreement’s independent-contractor language; the court also declined to strike the challenged summary-judgment materials and left most evidentiary disputes for trial.


Narayanasamy v. Issa, 435 F. Supp. 3d 388 (2020)