Flowers Foods, Inc. v. Brock
The Court holds that a worker who transports goods on an intrastate leg of an interstate journey can qualify for the Federal Arbitration Act's Section 1 exemption — which excludes from the Act contracts of employment of transportation workers engaged in interstate commerce — without ever crossing state lines or interacting with a vehicle that does.
Opinion: https://www.supremecourt.gov/opinions/25pdf/24-935_k53m.pdf
Case background
Flowers Foods, Inc., is one of the Nation’s largest producers of packaged baked goods, with bakeries in 19 States. To get its products to market, Flowers depends in part on franchisees who buy the rights to distribute Flowers’s products in specific geographic territories. Angelo Brock is one such franchisee serving the Denver area; he picks up Flowers’s products from a warehouse in Colorado and delivers them to local stores, all without leaving the State. In 2022, Brock sued Flowers in federal district court, alleging that the company had underpaid him and other distributors in violation of federal and state law. Flowers moved to compel arbitration under the Federal Arbitration Act, but the district court denied the motion and the Tenth Circuit affirmed, holding that Brock belonged to a class of workers engaged in interstate commerce and so fell within the Act’s § 1 exemption from arbitration.
Questions Presented
- Are workers who deliver locally goods that travel in interstate commerce — but who do not transport the goods across borders nor interact with vehicles that cross borders — “transportation workers” “engaged in foreign or interstate commerce” for purposes of the Federal Arbitration Act’s § 1 exemption?
Holding
A worker who transports goods on an intrastate leg of an interstate journey can qualify for § 1’s exemption from the Federal Arbitration Act without crossing state lines or interacting with vehicles that do. The statutory phrase “engaged in . . . interstate commerce” does not require either border-crossing or vehicle-touching; longstanding cases interpreting that language describe individuals who, like Brock, play a direct, necessary, and active role in moving goods between States while operating entirely within one of them.
The Court
Justice Gorsuch delivered the opinion for a unanimous Court.
What this episode contains
This episode is an AI-narrated reading of the majority opinion in Flowers Foods, Inc. v. Brock, written by Justice Gorsuch.
AI disclosure: The voice in this episode is AI-generated, using a machine learning model styled to loosely resemble the authoring justice. Tone, inflection, pacing, and emphasis are artifacts of the model and should not be attributed to Justice Gorsuch. The text being read is the Court’s published majority opinion, lightly adapted to improve readability for the spoken format.