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U.S. Supreme Court says airline supervisor is exempt from Federal Arbitration Act

July 2022 employment law letter
Authors: 
Emilia R. Janisch, Axley Attorneys

Voluntary arbitration agreements involving federal law are enforced under the Federal Arbitration Act (FAA). Section 1 of the FAA exempts certain classes of workers, however, from the enforcement of arbitration. The U.S. Supreme Court recently resolved a federal circuit court split over whether employees who load cargo for the transportation of goods are engaged in commerce and exempt from arbitration under Section 1.

FAA and Section 1 exemption

The FAA, enacted in 1925, favors arbitration to resolve employment disputes. Congress limited the FAA under Section 1, exempting seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce from arbitration.

In 2001, the Supreme Court held that Section 1 applies only to “transportation workers.” It also explained, however, that any such exempted worker must play at least a direct and necessary role in the flow of goods across state or international borders.

Dispute

As a Southwest Airlines ramp supervisor, Latrice Saxon’s job duties included supervising, training, and assisting ramp agents responsible for loading and unloading commercial cargo from airplanes. Specifically, ramp supervisors frequently performed the duties of ramp agents as part of their employment.

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