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A California appellate court has upheld a win for Lyft Inc. in a lawsuit brought by two people who were injured in a collision with a Lyft driver who was driving home from a separate job in a vehicle rented as part of a company program. 

The First District Court of Appeal found that Lyft could not be held liable under the doctrine of respondeat superior, which allows employers to be held legally responsible for the torts of employees committed within the scope of their employment.

According to the opinion, Lyft driver Jonathan Gaurano was driving a vehicle obtained through the company's "Express Drive program," which allows drivers to rent vehicles preapproved for use on the Lyft platform, when he struck plaintiffs Sabrina Marez's and Marissa Cruz's vehicles and caused "significant injuries." Gaurano, however, had not logged onto the Lyft ride-sharing platform on the day in question and was returning home to eat and rest after having worked at a separate job.

Plaintiffs lawyers at Galine, Frye, Fitting & Frangos argued that the rental program itself, which required drivers to complete 20 rides per month and drive exclusively for Lyft, led to the presumption that drivers were acting within the scope of their employment any time they used the vehicles, since they could log on to the app at any time. But the company and its lawyers at McGuireWoods pointed to Gaurano's testimony that he had not logged onto the Lyft app on the day of the accident and had no intention to do so.

"According to plaintiffs, any time these drivers were in their vehicles, there would be an increased possibility they would log onto the rideshare application, particularly if there were any heightened financial incentives offered for doing so (increased fares, driving bonuses, etc.). And that possibility would constitute a benefit to Lyft and bring any driving, for any reason, at any time, within 'the scope of business,'" wrote First District Associate Justice Sandra Margulies. "We decline to create so broad a rule."

Margulies, who was joined in the opinion by Division One Presiding Justice Jim Humes and Associate Justice Kathleen Banke in the opinion, found that there was no connection between Guarano's actions driving home from a separate job and Lyft's business. "The mere fact that Gaurano could have opted to drive for Lyft on the day in question instead of working at a gaming conference does not create such a nexus," she wrote. The opinion upholds a summary judgment ruling from San Francisco Superior Court Judge Harold Kahn.

Galine, Frye, Fitting & Frangos partner Ilya Frangos, who represents the plaintiffs, wasn't immediately available for comment Friday.