Facts

Plaintiffs Judith Smith, Julie Fuller, Sascha Bittner, and Tara Ayers are disabled, use motorized wheelchairs, and live in the Bay Area. Defendant Lyft, Inc. operates a transportation service on an app-based platform to match riders with drivers. Defendant offers a variety of ride "modes," all of which accommodate foldable wheelchairs. Defendant offered a Wheelchair-Accessible Vehicles (WAV) service giving ride accommodations to motorized wheelchairs, but did not offer this service in Alameda or Contra Costa Counties. In March, 2019, plaintiffs filed a class action complaint against defendant alleging violations of the Americans with Disabilities Act (ADA).

PLAINTIFFS' CONTENTIONS: Plaintiffs contended that defendant discriminates against motorized wheelchair users by failing to offer wheelchair-accessible rides. Plaintiffs contended that defendant offered "wheelchair access" mode only within San Francisco, and with greater restrictions than its standard mode. Plaintiffs contended that defendant should adopt proposed modifications (e.g. expansion of wheelchair access mode to Alameda and Contra Costa Counties, modification of the application settings to make the WAV option immediately visible to users, or raise prices to help pay for WAV) to defendant's policies, practices, or procedures.

DEFENDANT'S CONTENTIONS: Defendant contended that plaintiffs failed to propose a concrete modification to defendant's current policies, practices, or procedures. Defendant contended that WAV services would fundamentally alter defendant's business because WAVs are a new transportation service.

Result

Judgment entered in favor of defendant because plaintiffs did not carry their burden to prove that defendant discriminated against disabled individuals in violation of the ADA. Plaintiff was required to propose a concrete modification rather than merely propose that the district court order the defendant to undertake a trial-and-error process to try to find a proposed modification. Plaintiffs, therefore, established no entitlement to relief on their claim.