Bissonnette v. LePage Bakeries Park St., LLC

Background

Two men who bought territory rights to deliver and sell baked goods for a large bakery company sued the company over unpaid wages. Their contracts required disputes to be decided by arbitration under a federal law that generally enforces arbitration agreements. The distributors argued they fall into a narrow statutory exemption for “workers engaged in foreign or interstate commerce,” so the arbitration law should not apply to them.

Reasoning

The Court considered whether the exemption applies only to people who work for transportation companies. It relied on past decisions that define the exemption by what a worker actually does, not by the employer’s industry. The Court rejected a Second Circuit test that would require courts to decide whether a company’s main business is moving goods or people. The Court explained the exemption covers transportation workers who play a direct and necessary role in moving goods across borders, and that this focus on work performed avoids broad or open-ended results.

Real world impact

The ruling means courts should look at the worker’s actual duties, not the employer’s industry, when deciding the exemption. That could allow some delivery, loading, or distribution workers to avoid being forced into arbitration even when their employer is not a conventional transportation company. The decision also rejects an approach that would have required extensive discovery into a company’s revenue model before resolving arbitration issues.

Dissents or concurrances

The opinion was unanimous. Lower-court judges had disagreed about whether to focus on the worker’s tasks or the employer’s industry; that debate explains why the Supreme Court reviewed the case.