When truckers can avoid arbitration
New Prime v. Oliveira
In brief
Oliveira won: the Court ruled that his contract with New Prime was covered by the FAA’s exemption for work agreements.
- Where it stands
- Decided
Decided 8-0 · January 15, 2019 · Opinion by Justice Gorsuch
- What it’s about
- New Prime and truck driver Dominic Oliveira disputed whether the Federal Arbitration Act’s exemption for certain work contracts covered Oliveira’s independent-contractor agreement.
- Who it affects
- The FAA’s arbitration rules do not apply to Oliveira’s agreement with New Prime under this exemption.
Summary: written with AI from the case record.
What it's about
The Supreme Court ruled that “contracts of employment” includes any agreement to perform work, so Oliveira’s agreement fell within the exemption, and agreed with the First Circuit (affirmed).
The dispute turned on whether the FAA’s phrase “contracts of employment” includes independent contractors’ work agreements.
Question presented
1. Whether a dispute over applicability of the FAA's Section 1 exemption is an arbitrability issue that must be resolved in arbitration pursuant to a valid delegation clause. 2. Whether the FAA's Section 1 exemption, which applies on its face only to "contracts of employment," is inapplicable to independent contractor agreements.
What the Court decided
Holding
Because the Act’s term “contract of employment” refers to any agreement to perform work, Mr. Oliveira’s agreement with New Prime falls within §1’s exception. 857 F. 3d 7, affirmed.
- Result
- Affirmed
The Court's reasoning
The Court read the Federal Arbitration Act’s Section 1 phrase “contract of employment” to include any agreement to perform work. It therefore found Oliveira’s agreement covered by the exemption.
The vote
What's next
The Supreme Court’s review is complete, and the First Circuit’s ruling remains in place.
Documents
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
Show 2 moreShow fewer
Opinion added: opinion
Brief added: Questions Presented
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.