Southwest Airlines Co. v. Saxon

Background

A ramp supervisor for a major airline regularly loaded and unloaded baggage, mail, and commercial cargo on planes that traveled across state lines. She sued the airline in a putative class action alleging unpaid overtime under federal wage law. The airline tried to enforce her employment contract’s clause forcing individual arbitration. She argued that, under a Federal Arbitration Act exemption for "a class of workers engaged in foreign or interstate commerce," ramp supervisors who load cargo are excluded from the arbitration law. A trial court disagreed but the Seventh Circuit reversed, and the Supreme Court agreed to resolve the split with another appeals court.

Reasoning

The Court asked whether workers who actually load and unload cargo are part of a class "engaged in foreign or interstate commerce." It read the statute’s words in ordinary context, noting that “workers” and “engaged” focus on the work people do. Because ramp supervisors frequently perform cargo-loading tasks, the Court found they fit the statute’s class. The opinion relied on earlier cases and rules of interpretation saying the listed categories (like seamen and railroad employees) point to transportation-related work. The Court also used examples from the statute’s text—such as references to wharfage—to show loading is part of commerce. The Court rejected arguments that the exemption should be either industrywide or so narrow that only people who travel aboard the vehicle qualify.

Real world impact

The ruling means ramp supervisors who load interstate cargo fall outside the Federal Arbitration Act, so the airline cannot force individual arbitration under that federal law. Workers who actually load or unload interstate cargo can pursue class or collective wage claims instead of being limited to individual arbitration. The Court did not decide whether workers further removed from loading duties are exempt.