In a recent legal development, SDLA Courier Service, Inc. has filed an appeal against Samantha Peters in the Court of Appeal of the State of California, Second Appellate District, Division Six. The case, filed on May 14, 2024, challenges a lower court's decision denying SDLA's motion to compel arbitration under an employment agreement with Peters.
Samantha Peters initiated the lawsuit in Ventura County Superior Court on grounds of wage and hour violations. Peters worked for SDLA from September 2018 to July 2019 as a delivery driver and dispatcher. Upon her hiring, she signed a Mutual Agreement to Arbitrate Claims that mandated arbitration for any disputes arising from her employment. However, when Peters filed her lawsuit alleging individual and putative class claims for wage and hour violations, SDLA sought to compel arbitration based on this agreement.
The crux of the dispute revolves around whether the Federal Arbitration Act (FAA) applies to Peters' case. Specifically, SDLA argued that the FAA governed their arbitration agreement and that the transportation worker exemption under Section 1 of the FAA did not apply. The trial court disagreed, ruling that Peters was indeed a "last-leg Amazon delivery driver" engaged in interstate commerce and thus fell under the transportation worker exemption.
SDLA contended that their operations were purely intrastate since they only made local deliveries within California. However, the court found that despite delivering packages solely within state lines, these deliveries were part of a continuous interstate journey because many packages originated from out-of-state locations before reaching Amazon warehouses in California.
This legal interpretation aligns with precedents set by similar cases such as Betancourt v. Transportation Brokerage Specialists, Inc., where it was determined that last-mile delivery drivers for Amazon were exempt from FAA coverage due to their role in completing interstate commerce transactions. The Ninth Circuit's decision in Rittmann v. Amazon.com further supports this view by affirming that last-mile delivery drivers are engaged in interstate commerce even if they do not cross state lines themselves.
SDLA’s appeal was reviewed de novo by the appellate court given its basis on legal questions surrounding FAA applicability. Ultimately, the appellate court upheld the trial court’s decision, reaffirming that Peters' role as a last-leg delivery driver indeed qualified her for the transportation worker exemption under Section 1 of the FAA.
The plaintiffs seek relief including compensation for unpaid wages and other statutory damages related to wage and hour law violations. They also aim to secure injunctive relief preventing future violations by SDLA.
The judgment was affirmed by Justices Baltodano, Gilbert (Presiding Justice), and Yegan with costs awarded to respondent Samantha Peters. The case was presided over by Judge Benjamin F. Coats at Ventura County Superior Court. Legal representation included Ogletree, Deakins, Nash, Smoak & Stewart attorneys Tim L. Johnson and Nikolas T. Djordjevski for SDLA Courier Service Inc., while Justice Law Corporation attorneys Douglas Han, Shunt Tatavos-Gharajeh, Lawrence W. Beall and Christopher Petersen represented Samantha Peters.