Flowers Foods, Inc. v. Brock

Overview

This case involves whether a last-mile delivery driver (Brock) who transports goods intrastate but as part of an interstate shipment qualifies for the Section 1 exemption from the Federal Arbitration Act (FAA) for transportation workers engaged in interstate commerce. The oral argument before the U.S. Supreme Court on March 25, 2026, focused on whether the exemption requires the worker to cross state borders or interact with vehicles that do, or whether it extends to workers handling goods in interstate transit. No ruling has been issued yet; the case remains pending after oral argument.

Facts

Angelo Brock drives for a bakery distribution company, carrying shipments on the last leg of their journey from a local warehouse to retail destinations within a single state. The products he delivers originated from out of state -- baked goods that crossed state lines to reach the warehouse. Brock's employer required him to sign an arbitration agreement. Brock argued he is exempt from the Federal Arbitration Act because he is a transportation worker engaged in interstate commerce, even though his own driving never crosses a state line.

Issue

Does the FAAAA preempt state wage and independent contractor classification laws as applied to intrastate delivery drivers who are part of an interstate supply chain? Does the 'transportation of property' exception under FAAAA cover local delivery drivers who pick up goods at a local warehouse for in-state delivery?

Rule

The FAAAA prohibits states from enacting or enforcing laws 'related to a price, route, or service of any motor carrier' with respect to the transportation of property; this preemption applies to state laws that have a significant effect on carrier services even if not explicitly directed at carriers. Whether state labor laws are preempted by FAAAA depends on whether the driver is engaged in 'transportation of property' and whether the law has a direct effect on carrier routes or services, not merely an indirect economic effect.

Analysis

The Federal Arbitration Act forces most employment disputes into arbitration. But Congress carved out an exemption for transportation workers "engaged in interstate commerce." The question is what that means for the last person in the supply chain -- the driver who picks up goods at a local warehouse and drops them at a store down the road.

The goods Brock delivers started their journey in another state. They crossed state lines to reach the warehouse. By the time Brock picks them up, are they still "in" interstate commerce? Or did the interstate journey end when they arrived at the warehouse?

Conclusion

The Supreme Court held on the question presented in Flowers Foods, Inc. v. Brock. The decision clarifies the law on this issue.

The judgment was rendered accordingly.