In general, the Federal Arbitration Act (FAA) requires courts to enforce agreements to arbitrate. The big exceptions appear in FAA §1: "contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce."

Southwest Airlines v. Saxon (US Supreme Ct 06/06/2022) [PDF] raised the question of whether "any other class of workers engaged in foreign or interstate commerce" included Latrice Saxon, an airline ramp supervisor who frequently loads and unloads cargo alongside the ramp agents.

Although Saxon signed an agreement to arbitrate wage claims, a unanimous US Supreme Court holds that Saxon is indeed exempt, so she can bring her overtime claim in federal court rather than being required to arbitrate. Saxon belongs to a "class of workers engaged in foreign or interstate commerce" to which §1's exemption applies.

Both sides advanced extreme arguments, and the Court rejected both.

The airline argued that the exemption should cover only those workers who physically move goods or people across foreign or international boundaries—pilots, ship crews, locomotive engineers, and the like. To that, the Court said, "Here, §1's plain text suffices to show that airplane cargo loaders are exempt from the FAA's scope, and we have no warrant to elevate vague invocations of statutory purpose over the words Congress chose."

Saxon argued that all of the airline's workers – everyone from cargo loaders to shift schedulers to those who design Southwest's website – are covered by the exemption. To that, the Court compared the use of the word "seamen." Because "seamen" includes only those who work on board a vessel, they constitute a subset of workers engaged in the maritime shipping industry.