The question
Whether a worker must be employed in the transportation industry to qualify for the exemption from the Federal Arbitration Act in Section 1 for transportation workers engaged in interstate commerce.
Bissonnette v. LePage Bakeries Park St., LLC
What the Court decided
Reversed. A transportation worker does not need to work in the transportation industry to fall within the Section 1 exemption from the Federal Arbitration Act. The Second Circuit's rule, which limited the exemption to workers in the transportation industry, has no basis in the text of Section 1 or the Court's precedents. The relevant question is what the worker does, not what the employer's industry is.
How the justices split
UnanimousThe Court's opinion
Roberts, joined by Thomas, Alito, Sotomayor, Kagan, Gorsuch, Kavanaugh, Barrett, Jackson
Applying Circuit City and Saxon, the Court held that the Section 1 exemption turns on the work a worker performs, not the industry of the employer. The text of Section 1 refers to workers engaged in commerce and focuses on the performance of work. The Second Circuit's transportation-industry requirement has no support in the statutory text or the Court's precedents, and it would often turn on arcane questions about the nature of a company's services, requiring extensive discovery and adding expense and delay to FAA cases.
How we know · 5 sourced claims
The Section 1 exemption of the FAA is limited to transportation workers, as recognized in Circuit City Stores, Inc. v. Adams.
Source: syllabus, Held
The Second Circuit affirmed dismissal on the ground that the Section 1 exemption was available only to workers in the transportation industry and that petitioners were in the bakery industry.
Source: syllabus, Held
In Southwest Airlines Co. v. Saxon the Court declined to adopt an industrywide approach to Section 1, focusing on the work the employee performs rather than the industry of the employer.
Source: syllabus, Held
The Court held that a transportation worker need not work in the transportation industry to be exempt under Section 1 of the FAA.
Source: syllabus, Held
Chief Justice Roberts delivered the opinion for a unanimous Court.
Source: syllabus, lineup