Amazon Logistics, Inc., et al. v. Dirk Clinton, et al.

In Flowers Foods, Inc. v. Brock, 146 S. Ct. 1358 (2026), this Court held that a worker who transports goods on a purely intrastate leg of an interstate journey “sometimes” may be “engaged in interstate commerce” for purposes of the transportation-worker exemption of the Federal Arbitration Act, 9 U.S.C. § 1. Brock, 146 S. Ct. at 1363. The Court rejected a “bright-line rule” that such a worker could never be exempt and took equal care to explain that the exemption applies only “in certain circumstances,” depending on the specific facts of the intrastate transit the worker performs. Id. at 1365-1366. Acting before Brock, the California Court of Appeal exempted a class of local delivery drivers from the FAA for one reason alone: that “many” of the goods they picked up within California “originated outside [the State] and crossed state lines” at some earlier point. App., infra, 8a. The court denied any legal relevance to the evidence demonstrating that the goods came to rest in California warehouses for weeks on average before customers ordered them and that an outsized share of the delivered items were groceries and similar locally stocked goods. Id. at 12a-13a. The question presented is whether a local delivery driver is engaged in interstate commerce under Section 1 of the Federal Arbitration Act solely because some of the delivered goods previously crossed state lines, without regard to a break in the goods’ transit or their local character.