Flowers Foods, Inc. v. Brock

608 U. S. 380 (2026) · 5/28/26

The Federal Arbitration Act’s exemption from compelled arbitration for workers “engaged in . . . interstate commerce,” 9 U. S. C. §1, can apply to a worker who transports goods on an intrastate leg of an interstate journey and who does not cross state lines or interact with vehicles that do.

The Federal Arbitration Act (FAA) requires courts to enforce many private arbitration agreements, but it also provides that “nothing” in the law shall be used to compel arbitration in disputes involving the “contracts of employment” of any class of workers “engaged in . . . interstate commerce.” 9 U. S. C. §1. This case poses the question whether someone can qualify as a worker under the § 1 exemption if he never crosses state lines and never interacts with vehicles that do. Flowers Foods, Inc., is a large producer of packaged baked goods with bakeries in 19 States. To get its products to…

Held: A worker who transports goods on an intrastate leg of an interstate journey can qualify for § 1's exemption without crossing state lines or interacting with vehicles that do. Pp. 385–390. (a) The statutory text does not support a rule requiring workers to cross state lines or interact with vehicles that do. When the FAA was enacted, to “engage” meant to “take part in” something or to be “employ[ed]” or “involve[d]” in that thing. Black's Law Dictionary 661. And “interstate commerce” meant “[t]raffc,” “intercourse,” or “the transportation of persons or property between or among the…