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On the Alert

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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