Muller v. Roy Miller Freight Lines, LLC
246 Cal. Rptr. 3d 748
Cal. Ct. App. 5th2019Background
- Plaintiff William Muller, a former RMFL truck driver, sued RMFL in a putative class action for unpaid wages and other wage-and-hour claims after his employment ended.
- Muller never drove across state lines; his deliveries were entirely within California.
- RMFL is a licensed motor carrier; over 99% of the cargo it transports originates outside California.
- Muller signed an employment agreement requiring disputes to be resolved by binding arbitration under the Federal Arbitration Act (FAA).
- Trial court compelled arbitration for five of six claims but denied enforcement of arbitration as to Muller's unpaid-wages claim and stayed that claim pending arbitration of the others. RMFL appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the FAA applies or §1 exemption for "transportation workers" bars FAA coverage | Muller: §1 exempts him because he is a transportation worker engaged in interstate commerce | RMFL: FAA applies because Muller never crossed state lines and thus is not "engaged in" interstate commerce | Held: Exemption applies; Muller is a transportation worker because employer is in transportation industry and >99% of goods originated outside CA, so FAA does not govern his unpaid-wages claim |
| Whether Labor Code §229 allows suit for unpaid wages despite arbitration agreement | Muller: §229 permits judicial action on unpaid wages notwithstanding arbitration agreement | RMFL: If FAA applies, it would preempt §229 | Held: Because FAA is inapplicable, §229 applies and the unpaid-wages claim is not subject to arbitration (stay ordered pending arbitration of other claims) |
| Whether the question of classwide arbitrability is for court or arbitrator | Muller: Arbitrator should decide classwide arbitrability based on contract language delegating disputes | RMFL: Court should decide whether the agreement permits class arbitration | Held: Arbitrator decides classwide arbitrability because the agreement broadly delegated "all disputes" to the arbitrator; per state contract-law analysis, delegation question goes to arbitrator |
| Appealability of order about who decides class arbitration | RMFL: Appeals that portion of trial court's order | Muller: Order may not be appealable | Held: Unclear RMFL may appeal; even on merits, trial court correctly left class-arbitrability to arbitrator under Sandquist |
Key Cases Cited
- Circuit City Stores, Inc. v. Adams, 532 U.S. 105 (2001) (§1 FAA exemption limited to transportation workers; interpret "engaged in" narrowly)
- Sandquist v. Lebo Automotive, Inc., 1 Cal.5th 233 (2016) (delegation of class-arbitrability depends on contract interpretation under state law)
- Lenz v. Yellow Transp., Inc., 431 F.3d 348 (8th Cir.) (multifactor framework for determining §1 transportation-worker exemption)
- Kienstra Precast, LLC, 702 F.3d 954 (7th Cir.) (truckers who cross state lines are §1 transportation workers; interstate crossing dispositive in that case)
- Nieto v. Fresno Beverage Co., Inc., 33 Cal.App.5th 274 (2019) (intrastate driver exempt under §1 where employer in transportation industry and goods originated out-of-state)
- Performance Team Freight Systems, Inc. v. Aleman, 241 Cal.App.4th 1233 (2015) (FAA generally mandates arbitration for contracts "involving commerce"; review standards for arbitration orders)
- Muro v. Cornerstone Staffing Solutions, Inc., 20 Cal.App.5th 784 (2018) (interstate truck drivers who cross state lines qualify as transportation workers under §1)