Carmen Wallace v. Grubhub Holdings, Inc., 19-1564

Grubhub operates an online/mobile takeout marketplace and dispatches drivers to deliver restaurant-prepared meals.
Drivers signed Delivery Service Provider Agreements requiring arbitration of “any and all claims.”
Plaintiffs (drivers) sued for FLSA violations; Grubhub moved to compel arbitration under the FAA; district courts granted those motions.
Plaintiffs argued §1 of the FAA exempts their contracts because they are members of “any other class of workers engaged in foreign or interstate commerce.”
The court framed the key question as whether the drivers’ class is a transportation class actively engaged in moving goods across state or national lines (the §1 conception articulated in Circuit City).
The court rejected plaintiffs’ theory that mere delivery of goods that previously moved interstate suffices; it required the class itself to be centered on interstate transportation and affirmed the district courts’ orders compelling arbitration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Grubhub drivers fall within §1’s residual exemption as a “class of workers engaged in foreign or interstate commerce”	Drivers deliver goods containing components that traveled interstate/foreign, so their contracts are exempt	§1 is limited to transportation workers actually engaged in moving goods across state lines; incidental delivery of items does not make the class a transportation class	Drivers did not show their class is centered on interstate movement of goods; §1 does not apply; FAA governs and arbitration is compelled

Circuit City Stores, Inc. v. Adams, 532 U.S. 105 (interpreting §1’s residual clause by ejusdem generis to cover transportation workers actually engaged in movement of goods in interstate commerce)
AT&T Mobility LLC v. Concepcion, 563 U.S. 333 (reaffirming federal policy favoring arbitration)
Epic Sys. Corp. v. Lewis, 138 S. Ct. 1612 (FAA requires courts to enforce arbitration agreements according to their terms)
New Prime Inc. v. Oliveira, 139 S. Ct. 532 (§1’s “contracts of employment” covers independent contractors as well as employees)
Int’l Brotherhood of Teamsters Local Union No. 50 v. Kienstra Precast, LLC, 702 F.3d 954 (7th Cir.) (applying Circuit City’s transportation-worker framework)
McWilliams v. Logicon, Inc., 143 F.3d 573 (10th Cir.) (holding §1 covers employees actually engaged in channels of interstate commerce)
Hill v. Rent-A-Center, Inc., 398 F.3d 1286 (11th Cir.) (class must be defined by engagement in interstate transport; occasional interstate deliveries insufficient)
Lenz v. Yellow Transp., Inc., 431 F.3d 348 (8th Cir.) (distinguishing transportation workers from employees in non-transport roles)