Chambers v. Maplebear, Inc.
- Edgardo Ramos
- 1:21-cv-07114
- U.S. District Court · Southern District of New York
- 2
In Chambers v. Maplebear, Judge Ramos ordered the parties to address a possible stay while the Second Circuit reconsidered an arbitration exemption.
Joseph Chambers, Maplebear, Inc. doing business as Instacart, and the others similarly situated whom Chambers seeks to represent.
What happened
Chambers v. Maplebear, Inc. concerns Joseph Chambers’s action against Maplebear, Inc., doing business as Instacart, brought for himself and others similarly situated. The order discusses whether a recent Supreme Court decision affects an issue in the case.
The Supreme Court’s decision in Southwest Airlines Co. v. Saxon addressed which workers qualify as transportation workers exempt from the Federal Arbitration Act. The Second Circuit then agreed to reconsider part of its earlier decision in Bissonnette, which involved food-delivery drivers and that exemption.
Judge Edgardo Ramos ordered the parties to send letters by July 29, 2022, addressing whether Bissonnette could decide one or more issues in Chambers’s case and whether the case should be paused while the Second Circuit considers Bissonnette. The order did not itself decide those questions or impose a stay.
The detailed version
- Chambers v. Maplebear, Inc. · No. 1:21-cv-07114
- Edgardo Ramos
- July 21, 2022
Background
Joseph Chambers sued Maplebear, Inc., doing business as Instacart, individually and on behalf of all others similarly situated. The order does not describe the claims or the parties’ underlying factual positions.
On July 13, 2022, after the Supreme Court decided Southwest Airlines Co. v. Saxon, the Second Circuit granted rehearing by the full court in Bissonnette v. LePage Bakeries Park St., LLC. The rehearing concerned the Federal Arbitration Act’s transportation-worker exemption and the Second Circuit’s earlier conclusion that food-delivery drivers whose work occasionally required interstate travel did not qualify for that exemption.
In Saxon, the Supreme Court held that transportation workers must be actively engaged in transporting goods across borders through foreign or interstate commerce. It rejected deciding that question based on an entire industry. In Bissonnette, the Second Circuit had stated that the exemption was limited to workers involved in the transportation industry and had concluded that the plaintiffs were instead in the baking industry.
Order
Judge Ramos directed the parties to file letters by July 29, 2022. The letters must address whether Bissonnette may decide one or more issues in Chambers’s case and whether the court should stay, or pause, the case while the Second Circuit decides Bissonnette.
The order did not rule on whether the transportation-worker exemption applies, did not decide whether Bissonnette is dispositive, and did not order a stay. It was a procedural order directing additional submissions.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.