Florida Appeals Court Upholds Lyft’s Immunity Under TNC Statute in Wrongful Death Suit

Marshall Dennehey
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Marshall Dennehey

Abner v. Lyft Florida, Inc., et al., 2025 WL 2969993 (Fla. 3d DCA 2025)

Florida’s Third District Court of Appeal affirmed summary judgment in favor of Lyft in a wrongful death action stemming from an accident where a Transportation Network Company (TNC) driver collided with a motorcyclist. The plaintiff asserted claims of vicarious liability as well as negligent hiring and retention against Lyft.

The court found Florida’s TNC statute was applicable even though it was enacted only a few days prior to the accident. Further, the court concluded Lyft was not vicariously liable for the driver’s negligence because he was an independent contractor.

As to the claims of negligent hiring and retention, the court concluded the plaintiff provided an inadequate basis, despite the driver having received citations for speeding and reckless driving a few months before the accident, as well as a low rating from one passenger and a complaint of feeling scared from another.

This case reinforces that plaintiffs face significant hurdles based on statutory protections for transportation network companies.

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