Southwest Airlines Co. v. Saxon

Respondent 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 came to believe that Southwest was failing to pay proper overtime wages to ramp supervisors, and she brought a putative class action against Southwest under the Fair Labor Standards Act of 1938. 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. 9 U. S. C. §1. The District Court disagreed, holding that only those involved in “actual transportation,” and not those who merely handle goods, fell within §1’s exemption. The Court of Appeals reversed. It held that “[t]he act of loading cargo onto a vehicle to be transported interstate is itself commerce, as that term was understood at the time of the [FAA’s] enactment in 1925.” 993 F.3d 492, 494. Held: Saxon belongs to a “class of workers engaged in foreign or interstate commerce” to which §1’s exemption applies. Pp. 3–11. Credit: Justia US Supreme Court, available at: https://supreme.justia.com/cases/federal/us/596/21-309/