Griggs v. NHS Management LLC

On June 26, 2023, the U.S. Court of Appeals for the Eleventh Circuit issued a decision in Griggs v. NHS Management, LLC. The plaintiff, Tawana Griggs, and other dietary employees at Alabama nursing homes brought a Fair Labor Standards Act collective action against NHS Management, seeking unpaid overtime wages. The defendant moved to compel arbitration based on signed arbitration agreements. The district court denied the motion, ruling that the employees fell under the Federal Arbitration Act's "transportation worker" exemption because they frequently handled food and supplies that had moved in interstate commerce. The Eleventh Circuit reversed, holding that the employees' primary duties did not involve transporting goods across state lines and thus they did not qualify for the exemption. The case was remanded with instructions to grant the motion to compel arbitration.

The Eleventh Circuit reversed the district court's order denying the motion to compel arbitration, vacated the order, and remanded the case with instructions to grant the defendants' motion to compel arbitration.

Whether dietary employees at nursing homes, whose duties involved handling goods that had previously moved in interstate commerce, qualify as "transportation workers engaged in foreign or interstate commerce" under Section 1 of the Federal Arbitration Act, thereby exempting them from mandatory arbitration agreements.

The ruling narrowed the scope of the FAA's transportation worker exemption, limiting the ability of many low-wage employees to avoid arbitration clauses and proceed with collective actions. It reinforced the judiciary's pro-arbitration stance and will influence future exemption arguments in FLSA litigation.