Flowers Foods v. Brock

A worker who handles goods on a purely intrastate (within one state) leg of a broader interstate journey qualifies for the Federal Arbitration Act's (FAA) §1 exemption — meaning courts cannot force that worker into arbitration — even if the worker never personally crosses state lines or loads and unloads vehicles that do. Justice Neil Gorsuch authored the unanimous opinion of the Court. The FAA generally requires courts to enforce private arbitration agreements, but §1 carves out an exception for "contracts of employment" of workers "engaged in interstate commerce." The plain meaning of those words, drawn from dictionaries in use when Congress enacted the FAA in 1925, resolves the question. To "engage" meant to take part in, be employed in, or be involved in something. "Interstate commerce" meant the transportation of goods between points in one state and points in another — a definition that inherently includes intrastate stretches of a longer cross-border trip. A continuous delivery that begins in one state and ends in another is interstate commerce the entire way, even along the segments that stay within a single state's borders. A worker who handles goods during any direct, active, and necessary segment of that journey therefore participates in interstate commerce, regardless of whether the worker personally crosses a state line. Historical precedent reinforces this reading. In The Daniel Ball (1871), a steamship operating entirely within Michigan still counted as "engaged in commerce between the States" because it carried goods destined for other states. That principle — that multiple independent actors can each participate in a single interstate transaction even if each one stays within one state — maps directly onto the FAA's language. Flowers Foods argued that only workers who physically cross state lines or handle vehicles that do qualify for the exemption, but that bright-line rule finds no support in the statutory text and would produce absurd results, exempting only the driver who briefly crosses a border while excluding every other driver who moved the same shipment before and after that crossing.