[21-309] Southwest Airlines Co. v. Saxon

Southwest Airlines Co. v. Saxon

Wikipedia · Justia (with opinion) · Docket · oyez.org

Argued on Mar 28, 2022.
Decided on Jun 6, 2022.

Petitioner: Southwest Airlines Co..
Respondent: Latrice Saxon.

Advocates:

• Shay Dvoretzky (for the Petitioner)
• Jennifer D. Bennett (for the Respondent)

Facts of the case (from oyez.org)

Latrice Saxon is a ramp supervisor, which entails managing and assisting workers to load and unload airplane cargo for Southwest Airlines. Unlike ramp agents, supervisors like Saxon are not covered by a collective bargaining agreement and instead are required to arbitrate wage disputes, in accordance with their employment contract.

Notwithstanding the arbitration requirement, Saxon, on behalf of herself and other ramp supervisors, sued Southwest under the Fair Labor Standards Act for failing to pay overtime work. Southwest moved to stay the suit pending arbitration, or to dismiss it altogether in light of the arbitration agreement. Saxon argued that the Arbitration Act did not apply to her lawsuit because she and other ramp supervisors were “engaged in foreign or interstate commerce” and therefore exempt under Section 1 of the Act.

The district court ruled for Southwest, finding that a transportation worker must actually transport goods, not merely handle them at one end or the other of a network. On appeal, the U.S. Court of Appeals for the Seventh Circuit reversed, finding the act of loading cargo onto a vehicle to be transported interstate is itself commerce, and thus Saxon and the class of workers she represents are exempt from the Act.

Question

Is an airline employee who works as a ramp agent supervisor a “transportation worker” under Section 1 of the Arbitration Act and therefore exempt from the Act’s arbitration requirement?

Conclusion

An airline employee who works as a ramp agent supervisor, frequently loading and unloading airplane cargo, belongs to the “class of workers engaged in foreign or interstate commerce” and is therefore exempt from the Federal Arbitration Act’s arbitration requirement. Justice Clarence Thomas authored the unanimous 8-0 opinion of the Court.

The “class of workers” language of Section 1 refers not to what Southwest does generally, but what Saxon, as a worker, does specifically: physically loading and unloading cargo on and off airplanes. This work qualifies as being “engaged in foreign or interstate commerce,” as these workers are directly involved in transporting goods across state or international borders. Thus, Saxon falls within Section 1’s exception.

Justice Amy Coney Barrett took no part in the consideration or decision of the case.