I'm displaying my single use of Uber to date, but if the driver steals your phone, can you ever give him a one star review? I thought a couple of one stars and

I'm displaying my single use of Uber to date, but if the driver steals your phone, can you ever give him a one star review? I thought a couple of one stars and he never drives for Uber again. But if he inoculates himself from reviews, that is quite a hack of the system.