Bissonnette v. LePage Bakeries Park St., LLC
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Bissonnette v. LePage Bakeries Park St., LLC and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Bissonnette v. LePage Bakeries Park St., LLC.
The Supreme Court addressed whether the Federal Arbitration Act's exemption for 'contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce' applies only to workers in the transportation industry. The Court concluded that a transportation worker need not work in the transportation industry to be exempt under § 1 of the FAA. The Second Circuit's decision was vacated and remanded for further proceedings.
Holding
The single most important “bottom line” of what the Court decided in Bissonnette v. LePage Bakeries Park St., LLC.
The Court held that a transportation worker need not work in the transportation industry to be exempt from coverage under § 1 of the FAA.
Constitutional Concepts
These are the Constitution-related themes that appear in Bissonnette v. LePage Bakeries Park St., LLC. Click a concept to see other cases that involve the same idea.
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Why Commerce Clause is relevant to Bissonnette v. LePage Bakeries Park St., LLC
The case involves the interpretation of the Federal Arbitration Act, which is tied to interstate commerce, particularly focusing on whether certain workers are engaged in interstate commerce.
Syllabus excerpt (verbatim)The FAA provides generally that arbitration agreements are 'valid, irrevocable, and enforceable, save upon such grounds as exist at law or in equity for the revocation of any contract.' 9 U. S. C. § 2. It contains, however, an exception specifying that 'nothing herein contained shall apply to contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce.' § 1.
Key Quotes
Short excerpts from the syllabus in Bissonnette v. LePage Bakeries Park St., LLC that support the summary and concepts above.
A transportation worker need not work in the transportation industry to be exempt from coverage under § 1 of the FAA.
The relevant question was what the employee does at the airline, not what the airline does generally.
These requirements 'undermine[ ] any attempt to give the provision a sweeping, open-ended construction,' instead limiting § 1 to its appropriately 'narrow' scope.