Navigating the Federal Arbitration Act: A Case of Interstate Commerce and Independent Contractors

The most recent lawful chapter concerning the interpretation of Section 1 of the Federal Arbitration Act (FAA) has unfolded in a case concerning defendant Flowers Foods, Inc. and plaintiffs Margarito Canales and Benjamin Bardzik. Section 1 of the FAA excludes “agreements of employment of seamen, railroad employees, or any other category of workers engaged in foreign or interstate commerce” from the FAA’s general command that arbitration agreements be enforced. The district court, after considering arguments and evidence, denied the defendant’s motion to dismiss or compel arbitration, finding that the plaintiffs fit within the Section 1 exclusion.

In this blog post, we delve into the specifics of the case and explore the arguments presented.

The Case:

Accused Flowers Foods, Inc. is a Georgia-based holding company that possesses different subsidiary bakeries, including accused Lepage Bakeries Park Street, LLC, functioning out of Auburn, Maine. The lawsuit orbits the dispersal of baked items in Massachusetts via a “direct-store-delivery” system, encompassing autonomous distributors such as plaintiffs Canales and Bardzik.

Before 2018, the plaintiffs toiled as workers delivering baked goods through a provisional staffing agency. Subsequently, they created a distribution company, T & B Dough Boys Inc., which purchased distribution rights for Massachusetts routes. The dispute arose when the plaintiffs alleged misclassification as independent contractors and sought unpaid wages and damages.

Arguments and Findings:

Defendants claimed that plaintiffs, as freelancers, did not fall under the Section 1 exception, mentioning the comprehensive duties specified in the Distributor Agreements. Nevertheless, the district court opposed it, determining that the main function of the plaintiffs was the conveyance of goods, hence, they met the criteria as transportation employees under Section 1.
Defendants presented several arguments on appeal, challenging the district court’s decision. However, the court addressed only those arguments raised below and affirmed the denial of the motion to dismiss or compel arbitration.

Key Legal Points:

  • Field Focus: The defendants argued that the plaintiffs were not involved in the transportation field. However, recent precedent, as emphasized in Fraga, underscores that the emphasis should be on the worker’s position within the company, not the field as a whole. In this case, the court found that plaintiffs, by frequently delivering goods, qualified as transportation workers.
  • Primary Responsibilities: Defendants argued that plaintiffs’ primary responsibilities were those of business owners, not transportation workers. The court, relying on Fraga and Saxon, clarified that workers need not be primarily devoted to transportation to qualify for the Section 1 exemption. As long as they frequently engage in transportation work, they are considered transportation workers.


This lawful tale serves as yet another segment in the ongoing analysis of Section 1 of the FAA. The court’s verdict reaffirms the significance of concentrating on the character of the task executed by individuals rather than the all-encompassing sector in which the company operates. As the lawful surroundings progress, it remains vital for enterprises to prudently evaluate the functions and obligations of their employees in navigating the complexities of arbitration agreements and exceptions under the FAA.

As corporations struggle with the consequences of FAA provisions and exceptions, The Allied Outsourcing’s lawful proficiency comes to the forefront. Whether it be counseling on the organization of agreements, handling misclassification worries, or giving perspectives into the progressing legal scenery, The Allied Outsourcing offers customized resolutions to aid enterprises in comprehending and obeying the lawful structures overseeing employment associations and arbitration arrangements. In a changing lawful atmosphere, having a lawful service supplier like The Allied Outsourcing is vital for corporations desiring lucidity and conformity in their employment methodologies.

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