Supreme Court Expands Definition of Interstate Transportation Workers

High Court Rules Last-Mile Drivers Can Qualify as Interstate Workers

The U.S. Supreme Court issued a unanimous ruling Thursday that could significantly impact transportation companies, delivery contractors, and arbitration disputes across the logistics industry. In the case of Brock v. Flowers Foods, the Court determined that a transportation worker involved exclusively in in-state deliveries may still qualify as an interstate worker if their role is an essential part of a broader interstate supply chain.

The decision strengthens the legal standing of many last-mile delivery drivers and transportation contractors who operate entirely within one state but handle goods moving through interstate commerce.

Why the Case Matters

The ruling carries major implications for the application of the Federal Arbitration Act (FAA), particularly regarding whether transportation workers can pursue disputes in court rather than through mandatory arbitration agreements.

At the center of the case was Angelo Brock, a delivery franchise operator for Flowers Foods, the company behind well-known bakery brands such as Wonder Bread, Jumbo Honey Buns, and Butterscotch Krimpets. Brock’s deliveries were limited to the Denver region, and he never crossed state lines while performing his duties.

Despite that, Brock argued his work was still part of interstate commerce because the products he delivered moved through a national supply chain before reaching consumers.

Arbitration or Lawsuit? The Core Legal Question

The dispute originated from a 2022 lawsuit in which Brock challenged Flowers Foods over compensation-related issues. However, because Brock had signed an arbitration agreement as part of his franchise contract, the company argued the matter should be resolved privately through arbitration rather than in court.

The legal issue ultimately reached the Supreme Court: can a worker who never leaves their home state still be considered engaged in interstate commerce under the FAA?

Both the district court and the Tenth Circuit Court sided with Brock before the Supreme Court unanimously affirmed those decisions.

Justice Neil Gorsuch, writing the opinion for the Court, emphasized that a worker’s physical movement across state borders is not the only factor that determines whether they are engaged in interstate commerce.

“The Federal Arbitration Act requires courts to enforce many private arbitration agreements,” Gorsuch wrote. “But not all.”

The Court pointed directly to the FAA exemption covering transportation workers engaged in interstate commerce, reaffirming that the law applies broadly to workers who play a direct role in the interstate movement of goods.

Flowers Foods argued that interstate commerce status should only apply to workers who either physically cross state lines or directly interact with vehicles that do.

The Supreme Court rejected that interpretation.

Justice Gorsuch referenced the Court’s earlier decision in Southwest Airlines v. Saxon, which established that workers do not necessarily need to travel interstate themselves to qualify for the FAA exemption.

The Court further clarified that transportation workers participating in one segment of an interstate delivery process can still be considered part of interstate commerce, even if their specific route remains entirely intrastate.

“At least sometimes,” Gorsuch wrote, “a worker who transports goods on an intrastate leg of an interstate journey can qualify” for the exemption.

The “Krimpets” Example Explained

To illustrate the Court’s reasoning, Justice Gorsuch introduced a hypothetical example involving the transportation of Butterscotch Krimpets between two states.

In the scenario, multiple drivers participate in moving goods from a bakery in one state to a customer in another. One driver may cross the state border for only a few feet, while others remain entirely within their respective states.

According to the Court, all drivers involved are still participating in interstate commerce because each played a “direct, active, and necessary” role in completing the interstate delivery process.

The example reinforced the Court’s broader message: interstate commerce is defined by the movement of goods through the supply chain not simply by whether an individual driver crosses a state line.

Justice Gorsuch also pointed to historical legal precedent dating back more than 150 years, noting that similar interpretations have long existed in interstate commerce cases.

Flowers Foods Suffers Second Supreme Court Defeat

The Brock ruling marks the second unanimous Supreme Court loss for Flowers Foods in recent years involving worker classification and the FAA.

In a separate 2024 case, the company argued that certain workers were part of the baking industry rather than the transportation sector. That distinction would have required disputes to be handled through arbitration instead of litigation.

The Supreme Court rejected that argument as well, continuing a trend of broader interpretations of transportation-worker protections under federal law.

Transportation Attorneys React to the Decision

The ruling immediately drew attention from legal experts representing transportation companies and logistics providers.

Christopher Ward of Foley & Lardner described the decision as another example of the Supreme Court gradually expanding the transportation worker exemption under the FAA.

“For years, the Supreme Court described the exemption as narrow,” Ward explained, “but recent decisions show a broader interpretation.”

Ward added that lower courts may now apply the exemption even more widely, potentially affecting workers connected indirectly to transportation operations, including mechanics and support personnel.

Jennifer Bennett of Gupta Wessler, who represented Brock before the Supreme Court, praised the ruling as a major victory for last-mile delivery drivers.

“Without these workers,” Bennett said, “packages would not arrive, and products would never reach store shelves.”

Legal experts at the trucking-focused Scopelitis law firm noted that important questions still remain unresolved, particularly regarding whether independent business entities can qualify under the FAA transportation worker exemption.

More Legal Battles Could Be Ahead

Although the Supreme Court clarified key aspects of interstate transportation law, attorneys say the broader arbitration debate is far from settled.

Joe Diedrich, appellate litigation partner at Husch Blackwell, pointed out that many individual states have their own arbitration laws that may not include the same transportation-worker exemptions found in federal law.

As a result, employers could still attempt to enforce arbitration agreements under state statutes even when the FAA exemption applies.

The ruling nevertheless represents a major development for trucking companies, delivery carriers, logistics providers, and independent contractors operating within increasingly interconnected national supply chains.

For the transportation industry, the decision signals that the legal definition of interstate commerce may continue expanding well beyond the traditional image of drivers physically crossing state borders.