Bissonnette v. LePage Bakeries
The Facts
Neal Bissonnette distributed baked goods for LePage Bakeries in Connecticut. He and a colleague sued under state and federal wage laws. LePage moved to compel arbitration. Bissonnette argued the FAA's exemption for contracts of seamen, railroad employees, or other workers engaged in foreign or interstate commerce applied to him. The question was whether the exemption extends beyond transportation industry employees.
The Application
Bissonnette qualified for the FAA transportation worker exemption because he performed the work of transporting baked goods across state lines, even though his employer was a bakery rather than a transportation company. The Court's work-focused approach meant that his actual job duties, physically moving goods in interstate commerce, satisfied the exemption's scope, not the industry classification of his employer. As a result, he could invoke the exemption to block arbitration of his employment claims despite the arbitration agreement.
The Conclusion
**Bissonnette v. LePage Bakeries broadened the class of workers who can invoke the FAA's transportation worker exemption, making clear that the exemption turns on the nature of the work performed rather than the industry of the employer.** Delivery drivers, logistics workers, and others engaged in interstate movement of goods may now more readily avoid arbitration clauses in their employment contracts.
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Case Analysis
Overview
A bread delivery driver sought to invoke the Federal Arbitration Act exemption for transportation workers in interstate commerce to avoid arbitration of his employment claims. The Supreme Court held 9-0 that the FAA transportation worker exemption is not limited to workers in the transportation industry, but applies to any worker actually engaged in interstate transportation of goods.
Facts
Neal Bissonnette distributed baked goods for LePage Bakeries in Connecticut. He and a colleague sued under state and federal wage laws. LePage moved to compel arbitration. Bissonnette argued the FAA's exemption for contracts of seamen, railroad employees, or other workers engaged in foreign or interstate commerce applied to him. The question was whether the exemption extends beyond transportation industry employees.
Issue
Whether the Federal Arbitration Act's exemption for contracts of employment of transportation workers is limited to workers employed in the transportation industry, or whether it applies to all workers who are actually engaged in the work of transporting goods in interstate commerce regardless of industry.
Rule
The FAA exempts from its coverage contracts of employment of workers engaged in foreign or interstate commerce. This exemption is defined by the work the employee actually performs rather than by the industry of the employer. A worker who physically moves goods across state lines as a central job function qualifies for the exemption even if employed by a company not primarily in the transportation industry.
Analysis
Bissonnette qualified for the FAA transportation worker exemption because he performed the work of transporting baked goods across state lines, even though his employer was a bakery rather than a transportation company. The Court's work-focused approach meant that his actual job duties, physically moving goods in interstate commerce, satisfied the exemption's scope, not the industry classification of his employer. As a result, he could invoke the exemption to block arbitration of his employment claims despite the arbitration agreement.
Conclusion
**Bissonnette v. LePage Bakeries broadened the class of workers who can invoke the FAA's transportation worker exemption, making clear that the exemption turns on the nature of the work performed rather than the industry of the employer.** Delivery drivers, logistics workers, and others engaged in interstate movement of goods may now more readily avoid arbitration clauses in their employment contracts.
Notes
OT2023. Added via SCOTUS bulk import 2026-05-14
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