Lyft has won a Georgia appeals court ruling in a lawsuit brought by a passenger who was beaten unconscious by his driver, despite receiving two complaints about the driver's conduct in the eight days before the attack.
The Georgia Court of Appeals ruled Tuesday, October 27, 2026, that reports of unsafe driving and suspected drug or alcohol use gave Lyft insufficient reason to anticipate a violent assault. The passenger, William Evans, previously secured a $12.1 million judgment against driver Roy Sallie, who later pleaded guilty to aggravated battery.
Lyft approved Sallie to use its platform on August 28, 2020. The following day, a passenger gave him a one-star rating, complained about unsafe driving and reported feeling uneasy because the driver appeared to be under the influence of something. Lyft requested additional information but received no response and took no further action.
On September 4, another passenger submitted a one-star review and flagged Sallie for a suspected violation of the company's zero-tolerance drug and alcohol policy. Lyft took no action on that report.
Two days later, Evans booked a ride with Sallie to a rental car facility near Atlanta's airport. Sallie drove erratically, weaving between lanes despite light traffic, and repeatedly took wrong turns before Evans began directing him using his own GPS.
An argument escalated until Sallie pulled over and ordered Evans out of the vehicle. After Evans retrieved his luggage, Sallie exited the car, beat him unconscious and fled. Lyft removed Sallie from its platform following the attack.
Evans sued Sallie and Lyft in October 2020, accusing the company of negligence in allowing the driver to continue transporting passengers despite complaints about his conduct.
Court records also showed that Sallie had been charged with reckless driving in Virginia months before joining Lyft for allegedly traveling 94 mph in a 55 mph zone. The charge was reduced to improper driving, and Sallie entered a no-contest plea in August 2020.
Evans argued that the traffic offense and two passenger complaints should have prompted Lyft to remove Sallie from its platform before the assault.
A trial judge granted Lyft summary judgment, finding that Sallie's independent-contractor status defeated several claims seeking to hold the company responsible for his conduct. The judge also concluded that his driving record and reported safety violations failed to establish a foreseeable risk of violence.
Evans later obtained a $12,115,000 default judgment against Sallie, including compensation, punitive damages and attorney fees.
The appellate court upheld Lyft's dismissal, finding that Sallie's earlier conduct provided insufficient evidence of a tendency toward physical aggression. Georgia law requires a connection between alleged negligence and the resulting injury, known as proximate cause, including evidence that the type of harm was reasonably foreseeable.
Presiding Judge Doyle wrote that Sallie's improper-driving conviction was not among the offenses that automatically barred drivers from Lyft's platform under Georgia law. Even assuming the company should have removed him, his driving record offered no evidence that he was likely to physically assault a passenger.
The judges reached the same conclusion about the two suspected drug and alcohol violations, finding that the reports offered no evidence of prior aggression or violent behavior.
Judge Whitaker agreed with the ruling but wrote separately to question Lyft's handling of the early complaints. He said serious customer concerns and one-star ratings at the beginning of a driver's tenure should give rideshare companies reason to reconsider continuing their relationship with that driver.
Whitaker also stressed that passenger safety should remain a paramount concern for rideshare companies, regardless of their legal obligations.
The unanimous ruling leaves Lyft's summary judgment intact and the $12.1 million award against Sallie undisturbed.
