A federal judge in Washington, D.C., has dismissed a lawsuit against DoorDash involving a 2022 car accident, ruling that the delivery giant cannot be held responsible for a crash simply because its driver lacked insurance.
The case centered on a June 2022 collision between Diwann Tyer and Monique Griffin. According to court documents, Griffin had just finished her final delivery for DoorDash and was heading home when the two vehicles collided. Tyer filed suit against DoorDash, claiming the company was negligent for allowing Griffin to use its platform and make deliveries without verifying she had active auto insurance.
In the original complaint, Tyer detailed a list of driving errors by Griffin, including speeding, following too closely, and running a red light. Tyer argued that these actions, combined with DoorDash’s failure to check Griffin’s insurance status, led to “painful, permanent, and serious injuries.”
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However, U.S. District Judge Timothy J. Kelly sided with DoorDash’s motion to dismiss the case this week. The judge’s decision turned on the legal concept of “proximate cause”—the direct link between a defendant’s actions and the actual harm suffered.
Judge Kelly noted that while the complaint provided plenty of evidence regarding Griffin’s alleged poor driving, it failed to show how a lack of insurance actually caused the metal-on-metal impact. The court found that even if DoorDash had required proof of insurance, there was no indication that having a policy would have changed the way Griffin drove or prevented the accident from happening.
Under District of Columbia law, a person suing for negligence must prove that the defendant’s breach of duty was a “substantial factor” in the injury. In his memorandum, Kelly wrote that Tyer’s allegations didn’t come close to meeting that bar.
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“Nothing in the complaint… suggests that ‘the result would not have occurred’ if DoorDash had ensured that Griffin had insurance,” the judge stated.
Because the legal connection between the delivery platform’s administrative oversight and the physical crash was deemed too thin, the judge granted the motion to dismiss, effectively ending the litigation against the company.
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