Barrentine v. Arkansas-Best Freight System, 450 U.S. 728 (1981)
Relevant Facts: A group of unionized truck drivers sued a trucking company for wage theft under the Fair Labor Standards Act (FLSA). The truckers began by filing a grievance per their collective bargaining agreement, which was rejected without explanation. The truckers then filed a claim in federal district court under the FLSA, which the court rejected. The Court of Appeals affirmed, concluding that the petitioners’ submission to arbitration barred them from asserting an FLSA claim in court.
Question Before The Court: Whether an employee may pursue both contractual and statutory rights claims through arbitral or judicial proceedings.
The Opinion: The Court held that FLSA claims are not barred by prior submission to contractual dispute resolution procedures like arbitration. Noting that FLSA rights arise out of a statute to be considered separate from contractual rights, the Court provided, “Not all disputes between an employee and an employer are suited for binding resolution in accordance with the procedure established by [arbitration].” In reaching its decision, the Court explored when individual statutory rights outweigh the national policy favoring arbitration and engaged in a very long discussion of why arbitration is an inappropriate forum for the resolution of FLSA claims.
Unfortunately, the central holding of this case is gutted in subsequent cases, starting with Moses H. Cone Memorial Hospital v. Mercury Const. Co. 460 U.S. 1 (1983), decided just two years later.
