Why Did Georgia Rule for Lyft After a Driver Beat Williams Evans?

The ride to the airport

On September 6, 2020, Evans booked a Lyft to a rental-car facility away from the Atlanta airport terminals. The opinion says Sallie wove through lanes even though there was little traffic. He tried both terminals and a restricted parking area before Evans started giving directions from his own GPS.

Sallie pulled over and ordered Evans out. Evans took his luggage from the trunk. Sallie got out, beat him unconscious, and left. Lyft removed Sallie from the platform afterward. Sallie later pleaded guilty to aggravated battery.

Nine days on the platform

Lyft approved Sallie to drive on August 28, 2020. In April 2020 he had been charged in Virginia with reckless driving for allegedly going 94 mph in a 55 mph zone. The charge was reduced to improper driving. He pleaded no contest in August 2020. Lyft’s corporate representative testified that he believed a driver charged with reckless driving for going 94 in a 55 would be barred from the platform.

The next day, a passenger gave Sallie one star, complained of unsafe driving, and wrote that she or he “felt uneasy the whole time” and “felt like the driver was on something.” Lyft emailed that passenger for more detail. The passenger did not respond. Lyft did nothing further.

On September 4, another passenger gave Sallie one star and flagged him, without comment, for a suspected violation of Lyft’s zero-tolerance drug and alcohol policy. Lyft took no action. Two days later, Sallie picked up Evans.

Two judgments, two defendants

Evans sued on October 20, 2020, in the State Court of Clayton County. He claimed Lyft was liable for the assault on theories of vicarious liability and negligent hiring, training, supervision, and retention. Lyft answered that Sallie was an independent contractor.

Sallie did not answer. After Lyft moved for summary judgment, Evans added claims that Lyft was negligent for failing to disqualify Sallie based on his driving record and the drug and alcohol reports. Lyft argued that the assault was an intervening criminal act and was not a reasonably foreseeable result of anything Lyft did.

The trial court ruled for Lyft. It found the vicarious-liability and negligent-hiring claims failed because Sallie’s independent-contractor status was undisputed. It found the improper-driving conviction did not require removal under Georgia law. It found that neither passenger report put Lyft on notice of violent propensities.

Evans first appealed in December 2022. He withdrew that appeal after Lyft moved to dismiss it over a delay in filing transcripts. He then obtained a default judgment against Sallie. The opinion states: “After a damages hearing, the trial court entered a judgment against Sallie in the amount of $12,115,000, inclusive of compensatory damages, punitive damages, and attorney fees.” Evans then appealed the ruling for Lyft.

Why the majority ruled for Lyft

On appeal, Evans argued that Lyft’s failure to follow its own safety policies proximately caused his injuries. Presiding Judge Doyle’s opinion disagreed and affirmed.

The court asked whether Lyft could reasonably have foreseen this type of harm. Proximate cause is separate from whether someone wishes Lyft had removed Sallie sooner. Sallie was an independent contractor. The opinion still used Georgia’s foreseeability standard for a negligent relationship with a person who later commits a crime. That standard looks for some evidence of incidents similar to the behavior that caused the injury, and for the company’s knowledge of a tendency to cause that type of harm.

Neither reckless driving nor improper driving is a major traffic violation under OCGA § 40-5-142(18.2). Sallie had no other traffic violations in the preceding three years. See OCGA § 40-5-39(e)(4)(A). The conviction did not bar him from the platform. The court also said that even if the ticket should have kept him off Lyft, a prior speeding incident is not evidence of an incident similar to the violent assault.

The court treated the two passenger reports as if they showed Sallie had driven while intoxicated. It still found no evidence that Lyft knew of a propensity for aggression or violence, or that drug or alcohol problems made this assault reasonably foreseeable. Earlier Georgia cases had refused to treat alcohol or drug problems, standing alone, as notice of a later violent crime. The opinion distinguished cases with closer warnings, including a missed background check that would have shown burglary and kidnapping convictions, and a recent threat toward a supervisor.

The record contained no comparable sign that Sallie had aggressive or violent tendencies, or that Lyft knew of any. The court affirmed summary judgment for Lyft on the negligence claims tied to the driving record and the zero-tolerance reports. Judge Davis concurred.

The concurrence

Judge Whitaker concurred fully and specially. He agreed there was no record evidence that Sallie had shown aggressive or violent tendencies before the attack, or that Lyft knew of any. He agreed the trial court was right, under the proximate-cause cases, to grant summary judgment to Lyft.

He wrote separately about passenger safety. Serious complaints and one-star ratings at the start of a driver’s time on the platform should make a rideshare company pause before keeping that driver. Those complaints do not have to warn of violence for that practical point. The concurrence agrees with the judgment for Lyft. It is not a second ruling against Lyft, and it does not change the judgment against Sallie.

Case timeline

• April 2020: Sallie is charged in Virginia with reckless driving, later reduced to improper driving. He pleads no contest in August 2020.
• August 28, 2020: Lyft approves Sallie to drive on its platform.
• August 29, 2020: A passenger gives Sallie one star and writes that the driver seemed to be “on something.”
• September 4, 2020: A second passenger gives him one star and flags a suspected drug or alcohol violation.
• September 6, 2020: Sallie beats Williams Evans unconscious near the Atlanta airport.
• October 20, 2020: Evans sues Sallie and Lyft in the State Court of Clayton County, No. 2020CV02237.
• December 2022: Evans’s first appeal is filed and later withdrawn. The trial court then enters a $12,115,000 default judgment against Sallie.
• July 29, 2025: The trial court enters the order Evans appeals. He files his notice of appeal on August 7, 2025.
• October 27, 2026: The Georgia Court of Appeals affirms summary judgment for Lyft, No. A26A1152. Judge Davis concurs. Judge Whitaker concurs fully and specially.

What the appeal did not decide

The appeal challenged the summary judgment for Lyft. The $12,115,000 figure is the default judgment against Sallie after a damages hearing. The appeals court did not enter that amount against Lyft, and it did not retry the case against Sallie.

Georgia’s insurance requirements for rideshare companies are covered in the Georgia Uber and Lyft insurance guide.

Sources and case materials

• Georgia Court of Appeals, Evans v. Lyft, Inc., No. A26A1152, opinion, October 27, 2026 (PDF)
• Evans v. Lyft, Inc., No. A26A1152 (Justia)
• Georgia Court of Appeals docket, No. A26A1152

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