Curtis Hamrick v. Partsfleet, LLC, 1 F.4th 1337

U.S. Pack is a final-mile delivery company that contracts with drivers (labeled independent contractors) to make local deliveries from U.S. Pack warehouses stocked with goods shipped from other states and countries.
Drivers signed independent-contractor agreements containing an arbitration clause expressly governed by the Federal Arbitration Act (FAA).
Drivers (led by Hamrick) filed a collective FLSA action alleging misclassification and unpaid overtime; they opposed arbitration as exempt under the FAA’s §1 "transportation worker" exemption.
The district court denied U.S. Pack’s motion to compel arbitration, concluding the drivers were covered by the §1 exemption because they delivered goods that had moved in interstate/foreign commerce; it also denied compelling arbitration under state law.
U.S. Pack appealed. The Eleventh Circuit reviewed de novo whether the §1 exemption applied and separately addressed appellate jurisdiction over the state-law arbitration ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether drivers fall within FAA §1 transportation-worker exemption	Drivers: exemption applies because they transport goods that previously moved in interstate/foreign commerce; that suffices even if deliveries are intrastate	U.S. Pack: exemption requires (1) a class employed in the transportation industry and (2) that the class, in the main, actually engages in interstate/foreign commerce; final-mile intrastate routes don’t meet test	Reversed district court: applied wrong test. Remanded for district court factfinding under Paladino–Hill two-part test (class in transportation industry and class, in the main, actually engages in interstate commerce)
Whether this Court may review denial to compel arbitration under applicable state law	Drivers: district court correctly declined to compel under state law given FAA-language in contracts	U.S. Pack: asks this Court to exercise pendent appellate jurisdiction to review the state-law arbitration ruling alongside the FAA issue	Dismissed appeal as to state-law arbitration ruling for lack of appellate jurisdiction; pendent jurisdiction not warranted because state-law issue is not inextricably intertwined with the FAA question

Paladino v. Avnet Computer Techs., 134 F.3d 1054 (11th Cir. 1998) (holds §1 exemption requires employees actually engaged in transportation and frames test)
Hill v. Rent‑A‑Center, Inc., 398 F.3d 1286 (11th Cir. 2005) (adopts two-part test: class in transportation industry and, in the main, actually engages in interstate commerce)
Circuit City Stores, Inc. v. Adams, 532 U.S. 105 (2001) (construes §1 narrowly; exemption limited to transportation workers)
Walling v. Jacksonville Paper Co., 317 U.S. 564 (1943) (interprets "engaged in commerce" under FLSA; court rejects using that construction for FAA)
Walters v. Am. Coach Lines of Miami, Inc., 575 F.3d 1221 (11th Cir. 2009) (interprets "interstate or foreign commerce" in a different statutory context; not controlling here)
Wallace v. Grubhub Holding, Inc., 970 F.3d 798 (7th Cir. 2020) (rejects argument that delivering goods that previously moved interstate makes local drivers §1 transportation workers)
Palcko v. Airborne Express, Inc., 372 F.3d 588 (3d Cir. 2004) (Third Circuit exercised pendent appellate jurisdiction to review state-law arbitration ruling)
Moses H. Cone Mem’l Hosp. v. Mercury Constr. Corp., 460 U.S. 1 (1983) (explains federal body of law of arbitrability under the FAA)