Southwest Airlines Co. v. Saxon
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''Southwest Airlines Co. v. Saxon'', 596 U.S. ___ (2022), was a United States Supreme Court case related to the scope of the
Federal Arbitration Act The United States Arbitration Act (, codified at ), more commonly referred to as the Federal Arbitration Act or FAA, is an act of Congress that provides for judicial facilitation of private dispute resolution through arbitration. It applies in bo ...
, in which the Court unanimously held that cargo loaders and ramp supervisors employed at airports are exempt from the Federal Arbitration Act.


Background

Section 1 of the
Federal Arbitration Act The United States Arbitration Act (, codified at ), more commonly referred to as the Federal Arbitration Act or FAA, is an act of Congress that provides for judicial facilitation of private dispute resolution through arbitration. It applies in bo ...
, , exempts "contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce" from its scope. In its 2001 '' Circuit City Stores, Inc. v. Adams'' decision, the
Supreme Court of the United States The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
held the residual clause of Section 1 applies only to "transportation workers." Latrice Saxon was a ramp supervisor for
Southwest Airlines Southwest Airlines Co., typically referred to as Southwest, is one of the major airlines of the United States and the world's largest low-cost carrier. It is headquartered in Dallas, Texas, and has scheduled service to 121 destinations in the U ...
who directed the loading and unloading of cargo from the airline's flights. Saxon filed a lawsuit under the Fair Labor Standards Act of 1938 disputing Southwest's handling of overtime pay for ramp supervisors. The airline invoked an arbitration clause in Saxon's employment contract, and the district court dismissed her suit on that basis, finding that the Federal Arbitration Act did apply to her contract. The United States Court of Appeals for the Seventh Circuit reversed, holding Saxon was a transportation worker and her job involved her working in interstate commerce. Southwest filed a petition for a writ of certiorari.


Supreme Court

Due to the ruling in the Seventh Circuit contradicting another similar ruling in the United States Court of Appeal for the fifth circuit. Certiorari was granted in the case on December 10, 2021. Oral arguments were held on March 28, 2022. On June 6, 2022, the Supreme Court affirmed the Seventh Circuit in a unanimous decision.


References


External links

* 2022 in United States case law United States Supreme Court cases United States Supreme Court cases of the Roberts Court United States arbitration case law United States class action case law United States labor case law {{SCOTUS-case-stub