William Good v. Uber Technologies, Inc.

494 Mass. 116, 234 N.E.3d 262 (2024)

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William Good v. Uber Technologies, Inc.

Massachusetts Supreme Judicial Court
494 Mass. 116, 234 N.E.3d 262 (2024)

Facts

William Good (plaintiff) signed up for an account with Uber Technologies, Inc. (Uber) (defendant), which operated a ride-sharing app. During the sign-up process, Good was presented with a blocking page, i.e., a page Good had to complete before he could move on with the process. This blocking page had text encouraging a user to read Uber’s terms of use, a link to those terms, and a graphic of a clipboard with an X at the bottom near a pencil image. To complete the account-sign-up process, Good was required to click (1) a checkbox stating he had reviewed and agreed to Uber’s terms of use and (2) a separate button with the word “confirm.” Good clicked both of these. Good used Uber’s app to connect with driver Jonas Yohou (defendant) for a ride. During the ride, Yohou’s car collided with another vehicle. Good suffered a neck injury that left him paralyzed. Good sued Uber and Yohou in state court, seeking damages for his injuries. In its defense, Uber notified Good that provisions in Uber’s terms of use: (1) absolved Uber of any liability for injuries caused by a ride and (2) required all app users to use private arbitration to resolve any disputes with Uber, which meant that users had given up their rights to access the court system for any disputes. Relying on the second provision, Uber moved to compel the entire dispute to private arbitration. The trial court found that Good had not received reasonable notice of the arbitration provision and therefore had not truly agreed to give up his right to the court system. Accordingly, the trial court denied the motion to compel Good to arbitrate his claims. Uber appealed.

Rule of Law

Issue

Holding and Reasoning (Wendlandt, J.)

Dissent (Kafker, J.)

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