The U.S. Supreme Court narrowed the application of the Federal Arbitration Act (FAA) in its June 6 opinion in Southwest Airlines v. Saxon, 596 U.S. ____ (2002). The case, along with the earlier case New Prime v. Oliveira, 556 U.S. ____ (2019), represents the narrowest narrowing of the Supreme Court's broad holding in Epic Systems v. Lewis, 284 U.S. ____ (2018). In Southwest Airlines v. Saxon, the court answered the narrow question of whether an employee employed as a "ramp supervisor" fell within the Federal Arbitration Act's exemption of "contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce," concluding that the workers did fall within the exemption. The case does not presage a trend toward narrowing the application of the Federal Arbitration Act, and instead demonstrates that the court intends to encourage honoring arbitration agreements by insisting on a textual and precedential approach to the FAA.

Saxon was employed as a ramp supervisor at Southwest Airlines at Chicago Midway International Airport. At the beginning of her employment, she signed an employment agreement agreeing to arbitrate wage disputes individually. As a ramp supervisor, Saxon's job was to train and supervise teams of ramp agents. Ramp agents are employees who physically load and unload baggage, airmail and freight. Occasionally, ramp supervisors assist ramp agents in loading and unloading cargo. Saxon filed a putative class action of ramp supervisors against Southwest, alleging violations of the Fair Labor Standards Act (FLSA). Southwest moved to dismiss, citing Saxon's employment agreement that required arbitration pursuant to the FAA. Saxon argued that the ramp supervisors were exempt from the FAA pursuant to the exemption for "workers engaged in foreign or interstate commerce." The U.S. District Court for the Northern District of Illinois dismissed the case, agreeing that the exemption did not apply. The U.S. Court of Appeals for the Seventh Circuit reversed, finding that the loading of cargo to be transported interstate is "itself commerce." The Seventh Circuit's holding conflicted with an earlier decision of the U.S. Court of Appeals of the Fifth Circuit. The Supreme Court granted certiorari and found that Saxon belong to a "class of workers engaged in foreign or interstate commerce", and was exempt from arbitration.