Washington Court Expands FAA Transportation-Worker Exemption and Reaffirms Limits on Class Waivers in Wage Cases

When a warehouse worker loads boxes bound for out-of-state customers, are they a “transportation worker” under the Federal Arbitration Act? The Washington Court of Appeals recently said yes — again — in Sayaseng v. Geodis Logistics, LLC (No. 87485-3-I, Oct. 2025). The decision builds on the U.S. Supreme Court’s reasoning in Southwest Airlines v. Saxon and Washington’s own 2022 decision in Oakley v. Domino’s Pizza, extending the FAA’s transportation-worker exemption to another slice of the modern logistics workforce.

But Sayaseng doesn’t stop there. It also reinforces Washington’s strong public-policy stance against class-action waivers in wage-and-hour cases — even where an employer’s arbitration agreement might otherwise survive under state law. Together, these holdings mark another chapter in Washington’s deliberate effort to draw a boundary around what kinds of workplace disputes can, and cannot, be forced into private arbitration.

The Facts: Starbucks Distribution Workers and Arbitration Agreements

Geodis Logistics operates a warehouse in Auburn, Washington, distributing products to Starbucks stores across several states. Two workers — Bangorn and Brandon Sayaseng — brought a class action alleging violations of the state’s Minimum Wage Act, Wage Rebate Act, Industrial Welfare Act, and Wage Payment Act. Each had signed an arbitration agreement: one directly with Geodis, the other through a staffing agency.

Both agreements were governed by the Federal Arbitration Act (FAA), contained class-action waivers, and limited certain disputes to resolution in court. When the workers sued, Geodis moved to compel arbitration. The trial court denied the motion, finding that the employees were “transportation workers” exempt from the FAA under 9 U.S.C. § 1. The Court of Appeals affirmed.

Why the FAA Didn’t Apply: The Transportation-Worker Exemption

The FAA generally makes arbitration agreements “valid, irrevocable, and enforceable,” but it contains a narrow carve-out for “contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce.” Over the past decade, courts have wrestled with where that exemption ends — particularly as logistics, warehousing, and e-commerce blur traditional lines between local and interstate work.

In Sayaseng, the court followed the U.S. Supreme Court’s 2022 guidance in Southwest Airlines Co. v. Saxon, which held that ramp supervisors loading cargo for interstate flights fell within the exemption because they were “directly involved in transporting goods across state or international borders.” The Washington court reasoned that warehouse employees who move, package, and prepare goods destined for out-of-state shipment fall within that same category.

Because the Sayasengs’ work directly supported the interstate flow of Starbucks products, the FAA simply didn’t apply. And without the FAA, the employer couldn’t rely on its federal arbitration clause to force the dispute out of court.

When the FAA Falls Away: What Law Fills the Gap

Geodis argued that even if the FAA didn’t apply, its arbitration agreements could still be enforced under Washington law, particularly because one worker’s agreement included a “savings clause” preserving the rest of the contract if any term was found invalid. The court agreed that the FAA choice-of-law provision could be severed, but it ultimately found another, independent problem — the class-action waivers themselves.

Washington’s courts have long viewed class-action waivers in wage-and-hour disputes with deep skepticism. The Washington Supreme Court’s decision in Scott v. Cingular Wireless (2007) and the Court of Appeals’ more recent Oakley v. Domino’s Pizza (2022) both struck down such waivers as unconscionable and contrary to public policy. Sayaseng continues that line, holding that the right to pursue collective wage claims is a fundamental feature of Washington’s statutory framework for protecting workers.

Class Waivers and Public Policy

The court emphasized that class actions serve an essential role in ensuring that workers can vindicate wage-and-hour rights that might be too small or risky to pursue individually. The Minimum Wage Act and related statutes confer “substantive, non-negotiable, statutorily-guaranteed” rights — not merely procedural options. Forcing employees to waive collective mechanisms, the court said, would effectively exculpate employers from accountability.

That conclusion closely tracks the reasoning in Oakley, where the court invalidated Domino’s class waiver for Washington delivery drivers. There, too, the drivers were found exempt under the FAA’s transportation-worker carve-out — a symmetry that now makes Sayaseng look less like an isolated case and more like a developing state-level doctrine.

The Broader Takeaway for Employers and Counsel

For multistate employers and their counsel, the message is clear: choice-of-law provisions invoking the FAA won’t rescue an arbitration clause when the underlying work involves interstate transportation, and class-action waivers in Washington wage cases remain vulnerable. Even when agreements contain severability clauses, courts will strike the arbitration requirement if doing so is necessary to preserve workers’ statutory rights.

This is particularly relevant in logistics, fulfillment, delivery, and distribution centers — precisely the sectors where arbitration agreements are most common. Employers who use national templates drafted under the FAA should carefully evaluate whether their workforce includes employees who load, move, or handle goods in the interstate stream of commerce. The closer the connection to shipment across state lines, the stronger the argument for exemption.

Practical Implications for Arbitration Practitioners

For arbitrators and mediators, Sayaseng illustrates the importance of analyzing not just the wording of the arbitration agreement, but also the nature of the work relationship behind it. The transportation-worker exemption depends on function, not title — and it can apply even to employees who never personally cross state lines.

Moreover, as the Lexology commentary notes, these cases highlight the growing tension between federal pro-arbitration policy and state public-policy protections for workers. Washington has positioned itself as one of the more protective jurisdictions in this respect, treating wage rights as inherently public and collective in nature.

Counsel drafting or enforcing arbitration clauses in Washington should assume that:

• Workers tied to interstate logistics may qualify as exempt from the FAA.

• Any class-action waiver attached to wage-related claims faces a high risk of being voided.

• State law — not the FAA — will often fill the gap, and Washington’s statutory framework prioritizes employee protections.

A Note on Consistency and Federal Preemption

While the FAA’s preemption doctrine usually overrides state hostility to arbitration, the transportation-worker exemption removes those cases from the FAA entirely. Once outside federal coverage, states are free to apply their own rules. As a result, we now see a patchwork in which similar workers might be subject to arbitration in one jurisdiction but not another.

That inconsistency may eventually prompt renewed attention from Congress or the Supreme Court. But for now, Washington continues to chart an independent course — one that strongly favors transparency, public accountability, and access to collective remedies in employment disputes.

Conclusion

The Sayaseng decision is another reminder that arbitration agreements are not one-size-fits-all. When drafting, enforcing, or interpreting them, context matters — especially in industries built on the movement of goods across state lines.

For practitioners navigating this intersection of federal and state arbitration law, clarity and foresight are essential. And for parties seeking resolution of complex employment or commercial disputes, it’s critical to work with neutrals who understand the evolving limits of arbitration under both federal and state frameworks.

At Nationwide ADR, the focus is on just that — Unlocking Solutions for Demanding Cases.