Ahaji Amos v. Amazon Logistics, INC., No. 22-1748 (4th Cir. 2023)
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In this appeal from the district court, Plaintiffs A.A. and Kirk Amos Delivery and Courier, LLC (“Kirk Delivery”) challenged an order of the district court compelling the arbitration of various claims that Plaintiffs seek to pursue against Amazon Logistics, Inc. (“Amazon”). Conceding that each of their claims against Amazon falls within the scope of a binding commercial contract made between Kirk Delivery and Amazon in 2019 — and that an arbitration clause governed by the Federal Arbitration Act (the “FAA”) is set forth within that contract — Plaintiffs contend, in relevant part, that arbitration is not required due to the FAA’s exemption for “contracts of employment” with “transportation workers.”
The Fourth Circuit affirmed the district court’s judgment. The court held that the binding commercial contract is a business services deal struck between two corporate entities, not a “contract of employment” — the FAA’s so-called “transportation worker” exemption is inapplicable in these circumstances. The FAA thus mandates arbitration of all Plaintiffs’ claims.
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