US Supreme Court Rules Intrastate Truck Drivers Exempt from Federal Arbitration Act Arbitration Agreements
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TL;DR
- The US Supreme Court ruled truck drivers delivering goods on intrastate routes are exempt from FAA arbitration clause enforcement.
- The unanimous decision affirmed lower court rulings in favor of a Flowers Foods truck driver.
- Drivers engaged in transportation as part of an interstate journey qualify for the exemption even if not crossing state lines.
- The ruling directly impacts arbitration agreements used with delivery drivers in the transportation sector.
Overview
On November 5, 2025, the US Supreme Court issued a unanimous decision holding that truck drivers who deliver goods solely within one state, but as part of an interstate distribution process, fall within the Federal Arbitration Act's (FAA) transportation worker exemption. The Court sided with truck driver Angelo Brock against Flowers Foods, rejecting enforcement of an arbitration agreement in a wage dispute lodged by Brock.
What Happened
Angelo Brock, a truck driver delivering food products on local routes in Colorado for Flowers Foods, filed a lawsuit in 2022 alleging the company underpaid him and other drivers.
Flowers Foods sought to compel Brock to arbitrate the dispute based on an arbitration agreement, arguing that Brock, who operated only within Colorado, was not exempt from the FAA's arbitration requirements.
Lower federal courts, including the US Court of Appeals for the Tenth Circuit, sided with Brock, determining that his role transporting goods in the final-mile delivery of a larger interstate journey qualified him for the FAA exemption for transportation workers.
The Supreme Court agreed, concluding that a worker who participates in the intrastate segment of interstate commerce is covered by the FAA's exemption, even if they never cross state lines themselves.
Context
The Federal Arbitration Act generally requires enforcement of private arbitration agreements, but Section 1 excludes 'contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce' - commonly referred to as the transportation worker exemption.
The scope of this exemption, especially for workers whose duties are confined to intrastate deliveries but are tied to out-of-state shipments, has generated a split among federal appellate courts.
This decision clarifies that participation in the chain of interstate commerce, rather than physically crossing state lines, determines eligibility for the exemption.
Why It Matters
- The ruling limits companies' ability to compel arbitration with drivers handling intrastate legs of interstate deliveries.
- It affects how transportation and logistics companies draft contracts with drivers and delivery contractors.
- The decision may prompt further litigation to clarify which employment situations fall under the FAA exemption.