# Appeals Court Sends Uber Drivers Into Arbitration



## Ca$h4 (Aug 12, 2015)

http://www.law.com/sites/almstaff/2...ws&src=EMC-Email&et=editorial&bu=The Recorder

*Published: * Sep 7, 2016
*Appeals Court Sends Uber Drivers Into Arbitration*

SAN FRANCISCO - A federal appeals court on Wednesday handed Uber Technologies Inc. a major victory, ruling that drivers suing the company may be bound by arbitration agreements.

The U.S. Court of Appeals for the Ninth Circuit ruled that an arbitrator, not a federal judge, must decide whether the agreements used by Uber in 2013 and 2014 are enforceable.

The decision reverses a 2015 ruling that voided the company's arbitration agreements and allowed a driver class action to proceed against the company in court over claims that it violated background check laws.

"The district court should have ordered the parties to arbitrate their dispute over arbitrability &#8230; and we remand with instructions that it do so," Circuit Judge Richard Clifton wrote for the panel.

Clifton went on to offer strong signals that the court believes the agreements are valid, ruling that they were not "procedurally unconscionable," as the lower court had held.

The ruling in favor of the agreements is a coup for its legal team at Gibson, Dunn & Crutcher and could finally stem the tide of lawsuits that have dogged the company for the past several years.

"Arbitration is a fair, speedy and less costly alternative to class-action litigation. We've always believed our optional arbitration agreements should have applied in this case, and we're pleased with the court's decision today," Gibson Dunn's Theodore Boutrous Jr. said in a statement.

It also gives Uber new leverage in renegotiating an $84 million settlement with California and Massachusetts drivers. U.S. District Court Judge Edward Chen of the Northern District of California rejected the proposed settlement last month.

In the background checks case, Chen ruled that Uber's 2013 arbitration agreement was unenforceable. The judge objected in particular to Uber's procedures for opting out of arbitration, which he found so burdensome as to be "illusory." Drivers were required either to opt out in person at Uber's office in San Francisco or by overnight delivery service to its legal department.

But the panel disagreed with that conclusion-noting that some drivers did opt out. "Thus, the promise was not illusory," Clifton wrote. That the language providing for the opt-out was buried in the driver agreement "does not change this analysis," he added.

The panel, which was rounded out by Circuit Judges Richard Tallman and Sandra Ikuta, also had stern words for Chen's decision to go against Ninth Circuit case law in invalidating the 2014 agreement.

Even though that agreement contained a less burdensome opt-out clause than the previous version, Chen still found the agreement was procedurally unconscionable-explicitly contravening previous Ninth Circuit decisions, including one known as_ Kilgore v. Key Bank._

"The district court does not have the authority to ignore circuit court precedent, and neither do we," Clifton wrote in the decision.

Shannon Liss-Riordan, the plaintiffs lawyer suing Uber in the separate California and Massachusetts class actions, lamented the decision.

"This decision is not good for the class," Liss-Riordan said in a prepared statement. "The Ninth Circuit today endorsed Uber's attempt to use its arbitration agreement to avoid a systemic challenge to its classification of drivers as employees through a global class action."

The plaintiffs were represented in the background check case by Laura Ho of Goldstein, Borgen, Dardarian & Ho. She did not immediately respond to a request for comment.

_Ben Hancock can be reached at [email protected]. On Twitter: @benghancock_


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## Xylphan (Aug 26, 2016)

Oh, but you're still a partner. Riiiiggght.

Anyone who keep driving for Uber after this is just begging to be screwed over.


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## 4736353377384555736 (Aug 27, 2016)

If Liss-Riordan is anything more than a shyster, she'll appeal it to the Supreme Court.


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## rembrandt (Jul 3, 2016)

The big question is if a contract can void one of the constitutional right - seeking justice at the highest court of law in the country. Can any clause of a mutual contract supersede the US constitution which has sovreignty over all the laws in the country ? US constitution technically even supersede international laws within it's jurisdiction.


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## uberdriverfornow (Jan 10, 2016)

4736353377384555736 said:


> If Liss-Riordan is anything more than a shyster, she'll appeal it to the Supreme Court.


Exactly. She is basically required to send this on up to the Supreme Court. If she doesn't appeal to the Supreme Court then it's confirmed she's against the drivers and Uber somehow got to her.

Now it's up to the state Labor Board to step in and sue Uber on behalf of drivers in their state. They won't be beholden to the arbitration clause.

As we know already, this isn't a contract dispute, this is an employee status suit.

It should be obvious that if forced to go into arbitration, there is no way in hell any arbitrator is going to rule any of us as independent contractors so even in a worst case scenario we will all still win.

The problem is that Shannon now will try to sheister drivers by trying to push through another junk settlement.


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## observer (Dec 11, 2014)

4736353377384555736 said:


> If Liss-Riordan is anything more than a shyster, she'll appeal it to the Supreme Court.


Problem is the current Supreme Court is very pro business and pro arbitration clauses.


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## SEAL Team 5 (Dec 19, 2015)

Ca$h4 said:


> http://www.law.com/sites/almstaff/2016/09/07/appeals-court-sends-uber-drivers-into-arbitration/?cn=20160907&pt=Breaking News&src=EMC-Email&et=editorial&bu=The Recorder
> 
> *Published: * Sep 7, 2016
> *Appeals Court Sends Uber Drivers Into Arbitration*
> ...


Shannon is not happy. Same thing will most likely happen to the case she is representing. No multimillion dollar payout for her.


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## 4736353377384555736 (Aug 27, 2016)

observer said:


> Problem is the current Supreme Court is very pro business and pro arbitration clauses.


Not so much if Clinton is elected.


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## Allegro Acura (Aug 29, 2016)

Ca$h4 said:


> http://www.law.com/sites/almstaff/2016/09/07/appeals-court-sends-uber-drivers-into-arbitration/?cn=20160907&pt=Breaking News&src=EMC-Email&et=editorial&bu=The Recorder
> 
> *Published: * Sep 7, 2016
> *Appeals Court Sends Uber Drivers Into Arbitration*
> ...


Big Companies pay a lot of taxes while employing well connected lobbyists. State and Federal courts will toss voters under the bus in favor of tax paying multi billion dollar organizations.
after-all we are a capitalistic society. its all about $$$


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## Allegro Acura (Aug 29, 2016)

yes


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## UberBlackPr1nce (Dec 28, 2014)

observer said:


> Problem is the current Supreme Court is very pro business and pro arbitration clauses.


Right now the supreme Court is missing a justice, so if the vote is split then the decision stand with the lower court.


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## 4736353377384555736 (Aug 27, 2016)

UberBlackPr1nce said:


> Right now the supreme Court is missing a justice, so if the vote is split then the decision stand with the lower court.


It won't be missing a justice when the case would next be heard.


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## observer (Dec 11, 2014)

UberBlackPr1nce said:


> Right now the supreme Court is missing a justice, so if the vote is split then the decision stand with the lower court.


Which would not be good for drivers either.


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## UberBlackPr1nce (Dec 28, 2014)

4736353377384555736 said:


> It won't be missing a justice when the case would next be heard.


With this screwed up Gov, I wouldn't bet on it.


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## LADriver (Aug 28, 2014)

Ca$h4 said:


> http://www.law.com/sites/almstaff/2016/09/07/appeals-court-sends-uber-drivers-into-arbitration/?cn=20160907&pt=Breaking News&src=EMC-Email&et=editorial&bu=The Recorder
> 
> *Published: * Sep 7, 2016
> *Appeals Court Sends Uber Drivers Into Arbitration*
> ...


This does not affect the 2000 drivers (USA Today) that opted out of the arbitration agreement (I'm one of them). I was previously involved in a limo class action suit in California that only had 400 members (current and former Chauffeurs of one company) which settled after 3 years.

So, 2000 is still a sizable class action. The I.C. or Employer lawsuit should go forward as a class action. And these 2000 member can then include the remaining 300,000 blocked members through a PAGA suit. The difference is that a class action goes back 4 years from the date of filing. While a PAGA only goes back one year and 75% of proceeds goes to the State.


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## Fuzzyelvis (Dec 7, 2014)

4736353377384555736 said:


> Not so much if Clinton is elected.


If Trump is elected the Uber lawsuit will be the least of our worries.


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## 4736353377384555736 (Aug 27, 2016)

Fuzzyelvis said:


> If Trump is elected the Uber lawsuit will be the least of our worries.


Good point


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## cho (Mar 26, 2016)

LADriver said:


> The difference is that a class action goes back 4 years from the date of filing. While a PAGA only goes back one year and 75% of proceeds goes to the State.


How far back can an individual arbitration go?


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## LADriver (Aug 28, 2014)

cho said:


> How far back can an individual arbitration go?


Good question. I haven't researched it. But, I would say from the date it was signed/accepted/put into effect. So from the first day on the job. Correct me if I'm wrong 'yall armchair lawyers out there.


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## Michael - Cleveland (Jan 1, 2015)

4736353377384555736 said:


> If Liss-Riordan is anything more than a shyster, she'll appeal it to the Supreme Court.


Riordan was right all along - she said this would happen, and it did. The federal courts will not overturn this ruling.


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## Michael - Cleveland (Jan 1, 2015)

http://www.bloomberg.com/news/artic...-appeals-court-victory-over-arbitration-pacts
*Uber Gains Leverage Against Drivers With Arbitration Ruling*


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## uberdriverfornow (Jan 10, 2016)

> In a consolation for drivers, the appeals court said they will be able to proceed in court with claims brought under California's so-called bounty hunter law, the Private Attorneys General Act, or PAGA, which allows employees to step into the shoes of the state's labor commissioner to bring enforcement actions.


This is the key. As I said, the Labor Board should step in and sue on our behalf. Absent that, drivers can still sue under the above premise.

This ruling isn't really a big deal in terms of our eventual win. It just means it's going to take a little more time.

What might happen is that Uber might finally cave in and actually give forth a real settlement. But they need to be threatened with the above idea first.

The settlement we are looking for is major monetary damages AND a list of changes that allow us to actually be independent contractors for once.


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## SEAL Team 5 (Dec 19, 2015)

Fuzzyelvis said:


> If Trump is elected the Uber lawsuit will be the least of our worries.


With that ongoing nuke testing in North Korea I don't think any Presidential candidate will be the least of our worries.


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## Txchick (Nov 25, 2014)

4736353377384555736 said:


> Not so much if Clinton is elected.


Yep 1 vacancy to be filled.


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## Xylphan (Aug 26, 2016)

uberdriverfornow said:


> This is the key. As I said, the Labor Board should step in and sue on our behalf. Absent that, drivers can still sue under the above premise.
> 
> This ruling isn't really a big deal in terms of our eventual win. It just means it's going to take a little more time.
> 
> ...


Well, you are an independent contractor. You just have the shittiest contract I've ever laid eyes on.


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## tohunt4me (Nov 23, 2015)

Michael - Cleveland said:


> Riordan was right all along - she said this would happen, and it did. The federal courts will not overturn this ruling.


You can guess how this will come out


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## tohunt4me (Nov 23, 2015)

SEAL Team 5 said:


> With that ongoing nuke testing in North Korea I don't think any Presidential candidate will be the least of our worries.


Just air drop locusts on North Korea.


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## Dontmakemepullauonyou (Oct 13, 2015)

4736353377384555736 said:


> If Liss-Riordan is anything more than a shyster, she'll appeal it to the Supreme Court.


Oh yeah she will. Her 30mil score went out the window when the judge threw out the settlement.


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## Euius (May 19, 2016)

4736353377384555736 said:


> If Liss-Riordan is anything more than a shyster, she'll appeal it to the Supreme Court.


The Supreme Court is the one that found that contracts requiring arbitration agreements were enforceable. The Ninth circuit is simply following that ruling.

The case it did so is AT&T vs Concepcion. It was ruled 6 to 3


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## TangoDriver (Sep 9, 2016)

UBERITES, DON'T YOU ALL THINK THE OTHER BETTER SOLUTION FOR US DRIVERS IS TO UNIONIZE? HAS ANYBODY EVER CONSIDER COORDINATING WITH A LOCAL UNION ORGANIZATION FOR HELP? THEY HAVE THE MEANS & RESOURCES TO HELP. UBER MANAGEMENT IS SURE TAKING ADVANTAGE OF US IN EVERY WAY, EVERYDAY THEY CAN, UNTIL THEY CAN COME UP WITH A VIABLE DRIVERLESS CAR TO REPLACE US ALL.

HERE IS ANOTHER UBER PLOY: 

UBER IS SYSTIMATICALLY MIS CACULATING UBER POOL FARES ON YOUR PAYOUTS.

After I was told of this discovery by another Uberite at SFO Staging Area. I started monitoring my new Pool Fares more closely. Days after I picked up an Uber Pool ride from SFO to Palo Alto, CA 19.74 Uber miles. Total calculated fare was only $12.44 which I knew was impossible. I ran this route many times before on UberX but always more than $28. I complained via email & as usual I got the copy paste replies to frustrate me by asking so many useless question whose details and answer were already in my original email. After 4 emails from me, & 5 emails from Uber Driver Support team they finally admitted Uber calculation mistake & corrected the Total fare to $32+. Huge difference!

@@@@@@@@@@@@@@@@@@@@@

The BIGGEST QUESTION IS:

Did Uber preprogrammed UberPool miscalculations to cheat Unsuspecting & confused Uberites! If no one notices this deliberate computer mistakes, they'll get away with the money technically stolen from honest working drivers, the backbone of the Uber App. The MILLIONS UBER MGT IS COLLECTING can go to the settlement that Uber will owe all Uberites included in the Mis-Classification Class Action Suit. DO THE MATH: $20/day * 100,000 drivers across the Uber platform * 365 days. 

Will you be vigilant too, or will you just figuratively & literally sit it out & completely trust the system every time, every day?!?

Please spread the word to everyone in your Uberite network & localities. Also, please Post your comments & observations in this forum FOR YOUR INDIVIDUAL VOICE IS IMPORTANT. ALSO, be sure to collect those dispute emails for proof, I did.

LET'S UNIONIZE YOU ALL, AND GET OUR COLLECTIVE VOICES ECHO & HEARD FINALLY!!!

READ & POST.


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## cho (Mar 26, 2016)

How would this work then for drivers that did not initially opt-out of arbitration when they first joined (let's say in year 2014), but then opted-out of that new agreement in December 2015. I understand that we are no longer part of Riordan's class-action (thankfully) but can we file a lawsuit in court (not arbitrate) since we opted-out in December 2015? Maybe even go to small claims, file a new class-action, etc?


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## SurgeWarrior (Jun 18, 2016)

Ca$h4 said:


> http://www.law.com/sites/almstaff/2016/09/07/appeals-court-sends-uber-drivers-into-arbitration/?cn=20160907&pt=Breaking News&src=EMC-Email&et=editorial&bu=The Recorder
> 
> *Published: * Sep 7, 2016
> *Appeals Court Sends Uber Drivers Into Arbitration*
> ...


Just vote Teamsters and put Uber in their place!


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## SurgeWarrior (Jun 18, 2016)

TangoDriver said:


> UBERITES, DON'T YOU ALL THINK THE OTHER BETTER SOLUTION FOR US DRIVERS IS TO UNIONIZE? HAS ANYBODY EVER CONSIDER COORDINATING WITH A LOCAL UNION ORGANIZATION FOR HELP? THEY HAVE THE MEANS & RESOURCES TO HELP. UBER MANAGEMENT IS SURE TAKING ADVANTAGE OF US IN EVERY WAY, EVERYDAY THEY CAN, UNTIL THEY CAN COME UP WITH A VIABLE DRIVERLESS CAR TO REPLACE US ALL.
> 
> HERE IS ANOTHER UBER PLOY:
> 
> ...


https://teamster.org/organizing-victories/organizing-assistance-request-form


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## Euius (May 19, 2016)

TangoDriver said:


> UBERITES, DON'T YOU ALL THINK THE OTHER BETTER SOLUTION FOR US DRIVERS IS TO UNIONIZE?


No, and because I'm a contractor you can't force me to pay dues. Because I _won't_ pay dues, the organized shakedown groups called unions won't be interested in helping you


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## Scott.Sul (Sep 9, 2015)

4736353377384555736 said:


> Not so much if Clinton is elected.


Absolutely, because we all know _she_ can't be bought.


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## justaparttimer (Sep 5, 2016)

Fuzzyelvis said:


> If Trump is elected the Uber lawsuit will be the least of our worries.


Johnson/Weld 2016. #googlegary


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## TangoDriver (Sep 9, 2016)

Michael - Cleveland said:


> Riordan was right all along - she said this would happen, and it did. The federal courts will not overturn this ruling.


*********

UBERITES, RISE UP BEYOND THESE VISCIOUS CYCLE OF DEFEATIST THINKING.

As I read through thousands of comments of the many Featured Threads on this Community Forum there is but one common theme. There are many poster's here both well meaning, and from
Uber MGT Poseurs that are just promoting confusion, garbage or shallow arguments that are mostly self-serving. -- the agenda? To keep us all Uberites perpetually in the confused befuddled mode, and thus promote disunification. So long as we are fighting with each other by arguing incessantly with never ending topics that keep us in constant mode of "inaction" (that means sitting on our butts both literally & figuratively). Then Uber is persistently successful in their disinformation campaign.

WAKE UP PEOPLE!

Instead of lamenting the fact that a high court decided to follow the law upholding Arbitrarion over class action:

"The U.S. Court of Appeals for the Ninth Circuit ruled that an arbitrator, not a federal judge, must decide whether the agreements used by Uber in 2013 and 2014 are enforceable."

Remember the Mis-Classification Class Action Suit as originally filed, was from a handful of brave UBERITES only. Imagine if we all NOW ADD OUR SUPPORT to them and file our own individual LawSuit to add weight to theirs. IMAGINE WHAT A 100,000 INDIVIDUAL LAWSUIT OF THE SAME CHARACTER is going to do to the Arbitration legal system? It's a deluge that will eventually force it to gather all these together in one CLASS ACTION SUIT because IT'S NOW GOING TO BE MORE EXPENSIVE & IMPOSSIBLY REDUNDANT to process & Arbitrate 100K cases individually. For aren't they going to be one and the same process of hearing, presentation of evidence, and eventually, a judgement repeated 100,000 times?

Let's look at the facts;

Fact 1: Uber offered $100M to settle which was eventually rejected by the Judge.

It means the Judge was doing the drivers a Favor by doing so. He knows that Uber the initiator, indeed violated the State and Federal Labor laws, and all UBERITES deserve more than just $100M for which Uber will get only a slap on the wrist for creating this now $60B ++ violation (that's the latest approx Uber's pre-IPO Market Valuation). If Uber is not guilty, why would they offer $100M to drivers? As contribution to their individual B'day celebration? Oh, Common on!

Our continued, paralyzingly, & incessant arguments in forums such as this while persistently doing nothing ourselves, will mean that this Lawsuit will now go on for as long as Uber's -- Happy to Oblige, Lawyers can make this go on. All the while, Uber MGT is constantly find ways to scam UBERITES to accumulate money for the final day. For its very clear and they know it by now, that they did violate these Labor Laws, & Judge Chen saw this without exhibiting Bias towards UBERITES.

AND OUR/YOUR CONTINUED INACTION IS A FAVOR TO THE HAPPY UBER MGT THAT WE'VE BEEN CONSISTENTLY BASHING IN THIS FORUM. SO, SHOULD WE JUST CONTINUE BASHING EACH OTHERS MOUTH & BRAINS HERE?!?

STOP & THINK FOR A MOMENT!


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## DoUHaveAnyWater? (Sep 7, 2016)

> The district court should have ordered the parties to arbitrate their dispute over arbitrability &#8230; and we remand with instructions that it do so," Circuit Judge Richard Clifton wrote for the panel.


Judge Clifton had obviously been sitting in his chambers, hitting the crack pipe before and during proceedings. Either that or he's naturally mentally deficient.

The problem with saying that an arbitrator should have arbitrated whether or not the case should be resolved by arbitration is obvious - for the matter to be arbitrated under these circumstances then it must first be accepted that arbitration is appropriate, and if this has already been accepted then there is no need for an arbitrator to decide it. Therefore, by extension, any contract which contains an arbitration clause is automatically arbitratable. Only a fool would decree such flawed logic.


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## Null (Oct 6, 2015)

I opted out (twice; once when I first signed up and the 2nd time when they issued a 'new' agreement). This actually gives me leverage for individual action if it comes to it since the ruling has shrunk the class to practically nothing; Uber will likely want to pay me off.


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## Snowtop (Nov 11, 2014)

TangoDriver said:


> *********
> 
> UBERITES, RISE UP BEYOND THESE VISCIOUS CYCLE OF DEFEATIST THINKING.
> 
> ...


Please stop screaming like a little girl.


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## Fuzzyelvis (Dec 7, 2014)

Xylphan said:


> Well, you are an independent contractor. You just have the shittiest contract I've ever laid eyes on.


You can't contract yourself out of being an employee. If you could, Walmart and Mcdonalds would just have everyone wirking for them sign a contract saying they're a contractor and then treat them like employees.


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## Escoman (Jun 28, 2016)

Fuzzyelvis said:


> If Trump is elected the Uber lawsuit will be the least of our worries.


LOL if Clinton is elected We will be required to donate $1.50 of every fare to Clinton foundation.


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## robconner (May 9, 2015)

TangoDriver said:


> UBERITES, DON'T YOU ALL THINK THE OTHER BETTER SOLUTION FOR US DRIVERS IS TO UNIONIZE? HAS ANYBODY EVER CONSIDER COORDINATING WITH A LOCAL UNION ORGANIZATION FOR HELP? THEY HAVE THE MEANS & RESOURCES TO HELP. UBER MANAGEMENT IS SURE TAKING ADVANTAGE OF US IN EVERY WAY, EVERYDAY THEY CAN, UNTIL THEY CAN COME UP WITH A VIABLE DRIVERLESS CAR TO REPLACE US ALL.
> 
> HERE IS ANOTHER UBER PLOY:
> 
> ...


Hi, I work in Nyc and can't sleep so I just started reading and stumbled on to your post. I was driving a Juno pax last week who at the start seemed like some thug and was getting myself ready to hear 1hr plus worth of tough guy talk. Turns out he was prob the most educated pax about what's going with these apps that I've come across to date.

He's a dj and uses the apps multiple times a day and told me he speaks to all the drivers and knows exactly what uber is doing to the drivers and refuses to use them. One of the reasons being is a story he heard from an uber driver that had this same issue you were mentioning. He went back to check his statement and realized something wasn't right with the pay. So he started backtracking all his trips that he did the last 7 months. It turns out he was screwed by uber math for 1000's of dollars on his uber pool trips.

He complained constantly to the reps and they said that it was a "glitch" and that they were truly sorry. They winded up paying him that money but we all know or suspect that this is no glitch. Uber pool here in nyc is being pushed at a feverish level because I believe that fuber's end game is to take over mass transit. They are currently offering $79 unlimited uberpool rides per month here. That's the equivalent of buying a monthly metro card. They currently don't allow new drivers in nyc to cross dispatch, meaning even the guy with the $70000 suburban doesn't have much of a choice about picking up these rides. It's even set as the default 1 option when requesting a ride. In the end independent contractors don't have to pick up rides that they don't want to, but the reality is that all these new drivers are to uneducated to know this and the other reason is that I think that they believe it's easier to fool drivers with these uber crap jobs which over here sometimes have you picking up more than 3 pax making it a bit of a pain to keep up with how they are calculating everything.

Knowing this company this is def no glitch or mistake. If any "partner" actually picks ups this ubercrap, it would be in there best interest to check there statements.


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## tohunt4me (Nov 23, 2015)

Michael - Cleveland said:


> http://www.bloomberg.com/news/artic...-appeals-court-victory-over-arbitration-pacts
> *Uber Gains Leverage Against Drivers With Arbitration Ruling*


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## UberAnt39 (Jun 1, 2016)

Does this affect their agreement not to deactivate for low acceptance?


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## robconner (May 9, 2015)

A few people posted there convos with csr stating that you are an independent contractor and can pick up who you choose. You won't get deactivated for low acceptance but be careful about taking the request and then canceling afterward


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## REX HAVOC (Jul 4, 2016)

Ca$h4 said:


> http://www.law.com/sites/almstaff/2016/09/07/appeals-court-sends-uber-drivers-into-arbitration/?cn=20160907&pt=Breaking News&src=EMC-Email&et=editorial&bu=The Recorder
> 
> *Published: * Sep 7, 2016
> *Appeals Court Sends Uber Drivers Into Arbitration*
> ...


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## REX HAVOC (Jul 4, 2016)

This is a big "FU" from Uber to their partner drivers. I pretty clear that the judge is in the pocket of Heir Uber.


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## uberdriverfornow (Jan 10, 2016)

REX HAVOC said:


> This is a big "FU" from Uber to their partner drivers. I pretty clear that the judge is in the pocket of Heir Uber.


The judge was the one that ruled for us. It was the appeals court that overturned his ruling.


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## Ca$h4 (Aug 12, 2015)

*video: Beware the Fine Print | The New York Times *

*




Arbitration Everywhere, Stacking the Deck of Justice

http://www.nytimes.com/2015/11/01/b...-everywhere-stacking-the-deck-of-justice.html

*


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