Missouri appeals court ruling makes rideshare apps subject to product liability

An appeals court reversed and remanded a lower court’s decision in a case arising from a carjacking that killed the plaintiff’s son and involved a rideshare app.

The Missouri Court of Appeals, Eastern District reversed the trial court’s decision in a 2020 case involving the rideshare app, Lyft. Andrew Ameer, the plaintiff’s son and a Lyft driver, was killed during a carjacking in St. Louis. The ride had been fraudulently requested by minors using false information.

The plaintiff sued Lyft, asserting product liability claims of defective design, negligent design and failure to warn, as well as negligent training and overall general negligence. The petition alleged that the app lacked basic safeguards, such as identity and GPS verification, which enabled minors to anonymously request rides with criminal intent.

The trial court dismissed the case, ruling that Lyft was not a “product” under Missouri law and that the company did not owe a duty of care. The higher court disagreed on both counts.

The appellate court held that the Lyft app does meet the legal definition of a “product” under Missouri product liability law. The court acknowledged the app’s hybrid nature — it facilitates a service but was also designed, promoted and distributed by Lyft as a product for public use and profit.

The court referenced a similar case from 2024 out of Kansas, Doe v. Lyft. In that case, that plaintiff claimed she was sexually assaulted by a Lyft driver who had a criminal record, lacked a valid driver’s license and fraudulently used someone else’s license when applying for the job. The Kansas court ruled in the plaintiff’s favor, finding that Lyft app’s design was defective because it failed to properly verify that the driver’s photo matched the photo on the submitted driver’s license.

“Lyft’s role is different from a mere service provider because Lyft designed and placed the Lyft App into the stream of commerce for the general public, putting Lyft in the best position to control the risk of harm associated with the App caused by the design choices, similar to the designers of defective tangible products,” the opinion stated.  “We agree with the reasoning in Doe v. Lyft.”

The court noted that Lyft had implemented identity verification safeguards, such as identify and GPS verification, in other states but not in Missouri, and allowed fraudulent accounts to operate unchecked.

“Notably, to allow Lyft to be foreclosed from liability in Missouri for omissions in the design of the Lyft App which were allegedly implemented in other states would incentivize Lyft and other mobile application developers to … not put protections in place for Lyft drivers and customers in Missouri … and eliminate protections for its users in other states,” stated the opinion.

The court also sided with the plaintiff on the negligence claims, finding that her suit adequately alleged Lyft had a duty to protect drivers from foreseeable harm. Among the allegations were that the company was aware of prior carjackings involving similar fraudulent app usage, and that it failed to implement existing anti-fraud measures in Missouri.

Judge John P. Torbitzky partially dissented, concurring with the negligence claims but dissenting on the product liability claims.

In his dissent, he said the plaintiff’s claims focused more on Lyft’s business decisions, specifically its failure to implement passenger screening measures, rather than any concrete flaw in the app’s design or functionality.

“Plaintiff’s primary concern is that Lyft failed to screen and verify potential passengers,” Torbitzky stated in his dissent. “These allegations do not arise from a defect in the app itself. Rather … problems with Lyft’s business model and how it provides its ridesharing service.”

He added that the case represents how courts will need to continue grappling with how traditional legal frameworks apply to modern technology.

“This case presents a situation where the rapidly advancing technology sector has outpaced the development of our common law, leaving this Court to discern when and how to apply old rules to new technology,” he stated.

One of the plaintiff’s attorneys, Johnny M. Simon of The Simon Law Firm, said the appeals court’s decision was significant because it was the first time in Missouri that a court addressed whether an application like a ride share application is a product under the state’s product liability statute.

“The reason that it’s significant is that there’s been a lot of immunities granted to transportation network companies … under the current (Transportation Net Work Company) statute that prohibits, to a certain extent, people from suing vicariously for acts of their drivers,” Simon said. “Courts are slowly addressing this issue … We’re really looking forward to getting some questions to our answers.”

The case is Rochelle Ameer v. Lyft, Inc., Case No. ED112455.