The question
Whether a worker can qualify for the Federal Arbitration Act's Section 1 exemption for transportation workers engaged in interstate commerce even if he never crosses state lines and never interacts with vehicles that do.
Flowers Foods, Inc. v. Brock
What the Court decided
The Court held that a worker who transports goods on an intrastate leg of an interstate journey can qualify for the FAA's Section 1 exemption without crossing state lines or interacting with vehicles that do. The statutory text does not require a worker to cross state lines, and interstate commerce includes intrastate activity that is part of a continuous carriage between states. Historical precedent, including The Daniel Ball, supports treating a purely intrastate transporter as engaged in interstate commerce when moving goods that originate in or are destined for other States.
How the justices split
UnanimousThe Court's opinion
Gorsuch, joined by Roberts, Thomas, Alito, Sotomayor, Kagan, Kavanaugh, Barrett, Jackson
The opinion held that Section 1's transportation-worker exemption can reach a worker who never crosses state lines and never touches vehicles that do. It reasoned that at enactment, to engage meant to take part in or be involved in something, and interstate commerce meant transportation of goods between points in different states, which includes intrastate activity forming part of a continuous carriage. It cited The Daniel Ball and related cases holding that a carrier operating entirely within one State can be engaged in interstate commerce when moving goods destined for or brought from other States, and rejected Flowers's argument that those Commerce Clause cases do not bear on Section 1's scope.
How we know · 5 sourced claims
Gorsuch delivered the opinion for a unanimous Court.
Source: syllabus, lineup
The Court held that a worker who transports goods on an intrastate leg of an interstate journey can qualify for Section 1's exemption without crossing state lines or interacting with vehicles that do.
Source: syllabus, Held
The FAA's Section 1 exempts contracts of employment of workers engaged in interstate commerce from the Act's requirement that courts enforce arbitration agreements.
Source: syllabus, Held
The Court relied on The Daniel Ball, which held a steamer transporting goods entirely within Michigan was engaged in commerce between the States because it carried goods destined for or brought from other States.
Source: syllabus, Held
The Court rejected Flowers's argument that the cited Commerce Clause cases do not control the scope of Section 1 of the FAA.
Source: syllabus, Held