[24-935] Flowers Foods, Inc. v. Brock

Flower Foods, Inc. v. Brock

Justia · Docket · oyez.org

Petitioner: Flower Foods, Inc., et al.
Respondent: Angelo Brock.

Facts of the case (from oyez.org)

Petitioners—the defendants, collectively known as “Flowers”—produce and sell packaged baked goods throughout the United States. Flowers utilizes a “direct-store-delivery” system, contracting with individuals it classifies as independent distributors who purchase the rights to distribute its products within specific geographic territories. In 2016, Angelo Brock, operating as Brock, Inc., signed a “Distributor Agreement” with Flowers Baking Co. of Denver, LLC (“Flowers Denver”) to distribute products in parts of Colorado. This agreement, along with a “Personal Guaranty” Brock signed, included a mandatory Arbitration Agreement stipulating that disputes must be resolved under the Federal Arbitration Act (FAA).

Under this arrangement, Brock, Inc. placed orders for products, most of which were produced by Flowers bakeries located out of state, specifically to fill those orders. Flowers shipped the goods to a warehouse in Denver. Brock picked up the products at the warehouse, loaded them onto his own vehicle, and delivered them to his customers—various retail stores located only within Colorado. Brock himself did not cross state lines while making these deliveries. The business relationship soured, and Brock filed a lawsuit alleging Flowers misclassified its distributors as independent contractors to systematically underpay them, asserting violations of the Fair Labor Standards Act and Colorado labor law.

Brock filed his putative class and collective action in the U.S. District Court for the District of Colorado. Flowers moved to compel arbitration based on the parties’ agreement, but the district court denied the motion, concluding that Brock falls within the FAA’s § 1 exemption for transportation workers engaged in interstate commerce. On appeal, the U.S. Court of Appeals for the Tenth Circuit affirmed that decision.

Question

Are workers who deliver locally goods that travel in interstate commerce—but who do not transport the goods across borders nor interact with vehicles that cross borders—“transportation workers” “engaged in foreign or interstate commerce” for purposes of the exemption in Section 1 of the Federal Arbitration Act?