June 6, 2022
Decided June 6, 2022
Southwest Airlines Co. v. Saxon, No. 21-309
Today, the Supreme Court held that a ramp agent supervisor whose work frequently requires her to move baggage and other cargo on and off airplanes is a transportation worker exempt from the Federal Arbitration Act’s provisions requiring enforcement of arbitration agreements.
Background: The Federal Arbitration Act, or FAA, generally requires courts to enforce agreements to arbitrate. Section 1 of the FAA exempts from that requirement “contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce.” 9 U.S.C. § 1. The Supreme Court previously held that § 1’s residual clause covering workers engaged in foreign or interstate commerce applies only to “transportation workers.” Circuit City Stores v. Adams, 532 U.S. 105, 119 (2001).
Latrice Saxon, a ramp-agent supervisor who frequently loads and unloads cargo on and off airplanes, agreed to arbitrate wage disputes against Southwest on an individual basis. After Saxon brought a federal class action against Southwest seeking overtime wages, the airline moved to compel arbitration. Saxon opposed arbitration, arguing that she was a “worker engaged in foreign or interstate commerce” and thus was exempt from the FAA. The U.S. Court of Appeals for the Seventh Circuit agreed, holding that ramp agents and their supervisors are transportation workers exempt from the FAA.
Issue: Whether supervisors of airline ramp agents are “workers engaged in foreign or interstate commerce” exempt from the Federal Arbitration Act’s provisions requiring enforcement of agreements to arbitrate.
A ramp agent supervisor who frequently moves cargo on and off airplanes plays a direct role in the cross-border transportation of goods and therefore is exempt from the Federal Arbitration Act under § 1’s residual clause.
“We think it . . . plain that airline employees who physically load and unload cargo on and off planes traveling in interstate commerce are, as a practical matter, part of the interstate transportation of goods.”
Justice Thomas, writing for the Court
What It Means:
The Court’s opinion is available here.
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