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Southwest Airlines Co. v. Saxon

Southwest Airlines Co. v. Saxon

Supreme Court of the United States

March 28, 2022, Argued; June 6, 2022, Decided

No. 21-309.

Opinion

Justice Thomas delivered the opinion of the Court.

Latrice Saxon works for Southwest Airlines as a ramp supervisor. Her work frequently requires her to load and unload baggage, airmail, and commercial cargo on and off airplanes that travel across the country. ] The question presented is whether, under §1 of the Federal Arbitration Act, she belongs to a “class of workers engaged in foreign or interstate commerce” that is exempted from the Act’s coverage. We hold that she does.

Southwest Airlines moves a lot of cargo. In 2019, Southwest carried the baggage of over 162 million passengers to domestic and international destinations. Dept. of Transp., Bureau of Transp. Statistics (BTS), Passengers Southwest Airlines—All Airports (May 2, 2022) (online source archived at www.supremecourt.gov). In total, Southwest transported more than 256 million pounds of [*7]  passenger, commercial, and mail cargo. BTS, Air Carriers: T-100 Domestic Market (U. S. Carriers) (May 2, 2022) (online source archived at www.supremecourt.gov).

To move that cargo, Southwest employs “ramp agents,” who physically load and unload baggage, airmail, and freight. It also employs “ramp supervisors,” who train and supervise teams of ramp agents. Frequently, ramp supervisors step in to load and unload cargo alongside ramp agents. See 993 F. 3d 492, 494 (CA7 2021).

Saxon is a ramp supervisor for Southwest at Chicago Midway International Airport. As part of her employment contract, she agreed to arbitrate wage disputes individually. Nevertheless, when Saxon came to believe that Southwest was failing to pay proper overtime wages to her and other ramp supervisors, she brought a putative class action against Southwest under the Fair Labor Standards Act of 1938, 52 Stat. 1060, 29 U. S. C. §201 et seq.

Southwest sought to enforce its arbitration agreement with Saxon under the Federal Arbitration Act (FAA), 9 U. S. C. §1 et seq., and moved to dismiss the lawsuit. In response, Saxon invoked §1 of the FAA, which exempts from the statute’s ambit “contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce.” Saxon argued that ramp supervisors, like seamen and railroad employees, were an [*8]  exempt “class of workers engaged in foreign or interstate commerce.” Ibid.

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2022 U.S. LEXIS 2815 *

SOUTHWEST AIRLINES CO., PETITIONER v. LATRICE SAXON

Notice: The pagination of this document is subject to change pending release of the final published version.

Prior History:  [*1] ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SEVENTH CIRCUIT

Saxon v. Southwest Airlines Co., 993 F.3d 492, 2021 U.S. App. LEXIS 9370, 2021 WL 1201367 (7th Cir. Ill., Mar. 31, 2021)

Disposition: 993 F. 3d 492, affirmed.

CORE TERMS

cargo, interstate commerce, load, exemption, transportation, commerce, ramp, unload, airplane, airline, railroad employee, employees, ships, loaders, ejusdem generis, interstate, catchall, foreign commerce, canon, interstate transit, slip opinion, belongs, vessels, argues, travel

Business & Corporate Compliance, Arbitration, Federal Arbitration Act, Scope, Governments, Legislation, Interpretation