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Unanimous SCOTUS: Airline ramp
supervisor is
exempt from the FAA |
Southwest
Airlines v. Saxon (US Supreme Ct 06/06/2022)
http://case.lawmemo.com/us/southwest.pdf
Sent to Custom
Alerts™ subscribers on 06/06/2022
The Federal Arbitration
Act (FAA) requires courts to enforce agreements to arbitrate, but
§1 has an exemption for "contracts of employment of seamen,
railroad employees, or any other class of workers engaged in
foreign or interstate commerce."
The US Supreme Court now
holds – unanimously – that a ramp supervisor for Southwest
Airlines, who frequently loads and unloads cargo alongside the
ramp agents, belongs to a "class of workers engaged in foreign or
interstate commerce" to which §1's exemption applies. Therefore,
she is not required to arbitrate her claim.
Latrice Saxon,
a ramp supervisor for Southwest Airlines, trains and supervises
teams of ramp agents who physically load and unload cargo on and
off airplanes that travel across the country. Like many ramp
supervisors, Saxon also frequently loads and unloads cargo
alongside the ramp agents.
Saxon sued Southwest under the
Fair Labor Standards Act, claiming overtime wages.
Because
Saxon's employment contract required her to arbitrate wage
disputes individually, Southwest sought to enforce its arbitration
agreement and moved to dismiss. In response, Saxon claimed that
ramp supervisors were a "class of workers engaged in foreign or
interstate commerce" and therefore exempt from the Federal
Arbitration Act's coverage.
The US Supreme Court –
unanimously – agreed with Saxon, holding that Saxon belongs to a
"class of workers engaged in foreign or interstate commerce" to
which §1's exemption applies.
The parties disputed how to
define the relevant "class of workers." Saxon argued that because
the air transportation industry engages in interstate commerce,
airline employees, as a whole, constitute a "class of workers"
covered by §1. The Court rejected Saxon's industrywide approach,
holding that Saxon is a member of a "class of workers" based on
what she frequently does at Southwest—that is, physically loading
and unloading cargo on and off airplanes—and not on what Southwest
does generally.
The parties also disputed whether the class
of airplane cargo loaders is "engaged in foreign or interstate
commerce." The Court held that it is, saying, "To be 'engaged' in
'commerce' means to be directly involved in transporting goods
across state or international borders. Thus, any class of workers
so engaged falls within §1's exemption. Airplane cargo loaders are
such a class." *** [A]irline 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. They form 'a class of workers engaged in foreign or
interstate commerce.'"
Ultimately, the Court rejected
Saxon's argument that the "class of workers" includes all airline
employees who carry out the "customary work" of the airline,
rather than cargo loaders more specifically. The Court also
rejected Southwest's argument that only workers who physically
move goods or people across foreign or international
boundaries—pilots, ship crews, locomotive engineers, and the
like—are "engaged in foreign or interstate commerce."
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