Southwest Airlines Co. v. Saxon, 142 S. Ct. 1783

Latrice Saxon, a Southwest ramp supervisor, frequently loads and unloads baggage, mail, and freight and supervises ramp agents; her employment agreement required individual arbitration of wage claims.
Saxon sued Southwest under the FLSA for unpaid overtime as a putative class; Southwest moved to enforce the FAA arbitration clause.
Saxon invoked §1 of the FAA, arguing ramp supervisors are exempt as a “class of workers engaged in foreign or interstate commerce.”
The district court limited §1 to those in “actual transportation”; the Seventh Circuit reversed, holding loading interstate cargo is itself commerce; a circuit split existed with the Fifth Circuit.
The Supreme Court granted certiorari and held that workers who frequently load/unload cargo on interstate flights (including ramp supervisors who do so) fall within §1’s exemption from the FAA.

Issue	Plaintiff's Argument	Defendant's Argument	Held
How to define the relevant “class of workers”	All airline employees (industrywide) are the class	Class defined by workers’ conduct; only those actually engaged day‑to‑day in interstate commerce	Class is defined by the work members typically perform; Saxon is in the class because she frequently loads/unloads cargo
Whether cargo loaders are “engaged in foreign or interstate commerce”	Yes—airline work as a whole is interstate commerce; loading is part of that	No—only workers who physically accompany goods/people across borders (onboard) are engaged	Yes—physically loading/unloading interstate-bound cargo is directly part of interstate transportation and falls within §1
Use of ejusdem generis (interpret catchall by preceding terms)	The catchall supports an industrywide reading (all airline workers)	The catchall should be narrowed consistent with seamen/railroad attributes (onboard presence)	Ejusdem generis does not support industrywide or on‑board‑only readings; the catchall is read in light of the actual work performed by the class
Weight of FAA’s pro‑arbitration purpose	Text controls; exemption applies where plain language does	The FAA’s pro‑arbitration purpose counsels narrow exemptions to favor arbitration	Plain statutory text and context control; pro‑arbitration policy cannot override clear §1 language

Sandifer v. United States Steel Corp., 571 U.S. 220 (interpret statutes by ordinary contemporary meaning)
New Prime Inc. v. Oliveira, 139 S. Ct. 532 ("workers" focuses on performance of work)
Circuit City Stores, Inc. v. Adams, 532 U.S. 105 (§1 limited to transportation workers; apply ejusdem generis and meaningful‑variation)
Baltimore & Ohio Southwestern R. Co. v. Burtch, 263 U.S. 540 (loading/unloading interstate shipments is practically part of transportation)
Erie R. Co. v. Shuart, 250 U.S. 465 (un/loading is part of interstate transportation)
McDermott Int'l, Inc. v. Wilander, 498 U.S. 337 (definition of “seamen” as those employed on board a vessel)
Gulf Oil Corp. v. Copp Paving Co., 419 U.S. 186 (activities only perceptibly connected to interstate commerce insufficient)
United States v. American Building Maintenance Indus., 422 U.S. 271 (local services to interstate firms may not be “in commerce”)
AT&T Mobility LLC v. Concepcion, 563 U.S. 333 (use statutory purpose where text permits)
Ali v. Federal Bureau of Prisons, 552 U.S. 214 (ejusdem generis and interpreting catchall phrases)