Saxon v. Southwest Airlines Co.

Federal 7th Circuit Court
Civil Court
Federal Arbitration Act
Case Number: 
No. 19-3226
Decision Date: 
March 31, 2021
Federal District: 
N.D. Ill., E. Div.
Reversed and remanded

Dist. Ct. erred in dismissing plaintiff's Fair Labor Standards Act action and in compelling arbitration of plaintiff's claim based on arbitration clause contained in plaintiff's employment contract with defendant-airline. Record showed that plaintiff's job duties included duties as airplane cargo loader, and thus plaintiff was included in class of workers engaged in "commerce," as that term was understood at time Federal Arbitration Act (FAA) was enacted in 1925. As such, plaintiff is "transportation worker" whose contract of employment is exempt from coverage under section 1 of FAA. Accordingly, plaintiff can proceed on her FLSA claim in Dist. Ct.