Bissonnette v. LePage Bakeries Park St., LLC

Background

Two independent distributors who bought rights to sell and deliver baked goods in parts of Connecticut sued their supplier, a large baked-goods company, claiming unpaid wages and unlawful deductions. Their Distributor Agreements included separate arbitration promises requiring disputes to be resolved by private arbitration. The company asked federal courts to force arbitration. The district court ordered arbitration, and the federal appeals court affirmed, saying the statute’s exemption applies only to workers employed by transportation-industry companies.

Reasoning

The central question was whether the exemption applies because of the employer’s industry or because of what the worker actually does. The Court examined the statute’s wording and earlier cases and concluded the focus must be on the worker’s role—whether the worker performs transportation work—not on the employer’s overall business. The Court rejected the appeals court’s industry-based test as textually unfounded and said courts should assess the worker’s tasks. The Court vacated the appeals-court judgment but did not decide whether these particular distributors themselves qualify as transportation workers or work in interstate commerce.

Real world impact

Lower courts must evaluate whether a worker plays a direct, necessary role in moving goods across borders by looking at the worker’s duties, not the company’s revenue model. That approach may affect delivery drivers, franchise distributors, and others who move goods for suppliers or retailers. Because the Court left key factual questions open, many cases will still proceed through further litigation before final resolution.