Episode description

Welcome to Supreme Court Opinions. In this episode, you’ll hear the Court’s opinion in Bissonnette v LePage Bakeries Park St., LLC.

In this case, the court considered this issue: To be exempt from the Federal Arbitration Act, must a class of workers that is actively engaged in interstate transportation also be employed by a company in the transportation industry?

The case was decided on April 12, 2024.

The Supreme Court held that a transportation worker need not work in the transportation industry to be exempt from coverage under Section 1 of the Federal Arbitration Act. Chief Justice John Roberts authored the unanimous opinion of the Court.

In Circuit City v Adams, the Court held that Section 1’s exemption covers “transportation workers” based on the characteristics shared by the specific categories of “seamen” and “railroad employees” mentioned in the statute. In the more recent Southwest Airlines v Saxon case, the Court rejected an “industrywide” approach, emphasizing that the focus is on the work the individual performs, not the industry of their employer. The Court reasoned that imposing a “transportation industry” requirement would lead to complex line-drawing problems about what counts as that industry. Moreover, the statutory text and precedent do not support limiting “seamen” and “railroad employees” to particular industries. While there is a legitimate concern that Section 1 might be read too broadly, transportation workers play a direct and necessary role in the interstate transport of goods, ensuring that the exemption remains appropriately narrow. Therefore, the appeals court erred in compelling arbitration solely because the workers were in the bakery industry.

The opinion is presented here in its entirety, but with citations omitted. If you appreciate this episode, please subscribe. Thank you.