Summary
The Supreme Court held that a transportation worker need not work for a company in the transportation industry to fall within the Federal Arbitration Act's section 1 exemption. The Court vacated the Second Circuit's judgment, which had applied an industry-based requirement, and remanded for further proceedings concerning whether the petitioners otherwise qualify as exempt transportation workers engaged in interstate commerce.
Topics
Practice areas
Questions Presented
- Whether a transportation worker must work for a company in the transportation industry to qualify for the exemption from coverage under § 1 of the Federal Arbitration Act.
Holdings
- A transportation worker need not work in the transportation industry to fall within the FAA § 1 exemption. The exemption turns on the nature of the worker's work, not the industry of the employer.
- The Court did not decide whether petitioners were transportation workers based on the work they performed or whether they were engaged in foreign or interstate commerce because they delivered baked goods only within Connecticut.
Key quotations
“A transportation worker need not work in the transportation industry to fall within the exemption from the FAA provided by §1 of the Act.” (256)
“That language focuses on “the performance of work” rather than the industry of the employer.” (253)
“In other words, any exempt worker “must at least play a direct and ‘necessary role in the free flow of goods’ across borders.”” (256)
Factual background
Neal Bissonnette and Tyler Wojnarowski were franchise distributors who purchased rights to distribute Flowers Foods products in portions of Connecticut. They retrieved baked goods from a warehouse and delivered them to local retailers, allegedly spending at least forty hours per week delivering products. Their responsibilities also included finding retail outlets, advertising, setting up displays, ordering and stocking products, and maintaining inventories. Their agreements contained arbitration provisions, and they sued alleging unlawful wage deductions, failure to pay overtime, and unjust enrichment.
Procedural history
Petitioners filed a putative class action alleging violations of state and federal wage laws. The District Court dismissed the case in favor of arbitration, concluding that petitioners were not transportation workers because of their broader distribution responsibilities. The Second Circuit affirmed on the alternative ground that petitioners worked in the bakery industry and therefore did not fall within the FAA's transportation-worker exemption. The Supreme Court granted certiorari, vacated the judgment, and remanded.
Remand instructions
The case was remanded to the Second Circuit for further proceedings consistent with the opinion, including consideration of alternative grounds for arbitration not decided by the Supreme Court.