Facts of the Case
Angelo Brock contracted with a subsidiary of Flowers Foods, a national baked-goods producer, to distribute its products to retail stores within Colorado, picking up goods at a Denver warehouse that had mostly been shipped from out-of-state bakeries; he never crossed state lines on his routes. When Brock brought a class action alleging Flowers misclassified its distributors as independent contractors, Flowers moved to compel arbitration under the parties' agreement. The district court denied the motion, holding Brock fell within the Federal Arbitration Act's Section 1 exemption for transportation workers engaged in interstate commerce, and the Tenth Circuit affirmed.
Questions
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 exemption in Section 1 of the Federal Arbitration Act?
Conclusions
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On May 28, 2026, the U.S. Supreme Court unanimously held in Flowers Foods, Inc. v. Brock that a worker who transports goods on an intrastate leg of an interstate journey qualifies for the Federal Arbitration Act's Section 1 transportation-worker exemption even if the worker never crosses state lines or interacts with vehicles that do.