C.K. Sales Co., LLC, et al. v. Margarito V. Canales, et al.

The Federal Arbitration Act (“FAA”) does not “apply to contracts of employment of seamen, railroad employees, and any other class of workers engaged in foreign or interstate commerce.” 9 U.S.C. § 1. This Court has afforded § 1 a “narrow construction” and held that its residual clause (“any other class of workers”) applies only to “contracts of employment of transportation workers.” Circuit City Stores, Inc. v. Adams, 532 U.S. 105, 115–19 (2001). This Court has further clarified that “transportation workers” include only those classes of workers who “play a direct and ‘necessary role in the free flow of goods’ across borders.” Sw. Airlines Co. v. Saxon, 596 U.S. 450, 458 (2022) (quoting Circuit City, 532 U.S. at 121). The question presented is whether § 1 applies to a class of workers who do not work in the transportation industry, but instead market, sell, and distribute baked goods within defined intrastate territories.