Southwest Airlines Co. v. Saxon

“[A]ny class of workers directly involved in transporting goods across state or international borders falls within [the Federal Arbitration Act] §1’s exemption.”

Respondent worked for Petitioner in a supervisory position which occasionally loads and unloads cargo onto planes. Respondent filed a putative class action suit over failure to pay overtime wages, despite signing an arbitration agreement to arbitrate all employment disputes individually. Petitioner moved to compel arbitration and dismiss the suit based on Federal Arbitration Act (FAA), while Respondent argued §1 of the FAA exempts “contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce.” (Emphasis added). The District Court ruled in favor of Petitioner. The Court of Appeals reversed. The Supreme Court agreed with the Court of appeals, holding that “any class of workers directly involved in transporting goods across state or international borders falls within §1’s exemption.” “Class of workers” refers to the conduct of the class of workers, not narrowed specifically to the employee as Petitioner contended, or broadened to the industry worked as Respondent argued. Based on the narrowing language of “engaged,” paired with the ejusdem generis canon of statutory interpretation as applied to “seamen [and] railroad employees,” contracts of transportation workers are exempted by §1.  Circuit City Stores, Inc. v. Adams, 532 U. S. 105, 119 (2001). Cargo loaders, such as Respondent, fall within the category of transportation workers. AFFIRMED.