Kendal Bellard v. Henry A. Hollier - Louisiana Court of Appeal Opinion

Louisiana Court of Appeal

Filed March 9th, 2026

Detected March 9th, 2026

Summary

The Louisiana Court of Appeal reversed a lower court's decision, ruling that a delivery driver's employment contract is exempt from arbitration under the Federal Arbitration Act. The court found that the driver, as a transportation worker involved in interstate commerce, falls under the Act's exemption.

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What changed

The Louisiana Court of Appeal, First Circuit, granted supervisory writs and reversed a portion of the trial court's judgment that had granted an Exception of Prematurity filed by Amazon Logistics, Inc. The appellate court determined that Kendal Bellard, a delivery driver for Amazon, is a transportation worker whose employment contract is exempt from arbitration under Section 1 of the Federal Arbitration Act (FAA). This exemption applies because Bellard's work, delivering packages that originate within the flow of interstate commerce, places him within the scope of the FAA's exclusion for such workers.

This ruling has significant implications for employers utilizing independent contractors or employees in delivery services that cross state lines. Companies relying on arbitration agreements with such workers may find those agreements unenforceable. Regulated entities should review their arbitration clauses and employment contracts for delivery personnel engaged in interstate commerce to ensure compliance with the FAA's exemptions. Failure to do so could result in arbitration agreements being invalidated, leading to potential litigation in state or federal courts rather than arbitration proceedings.

What to do next

Review arbitration agreements for delivery personnel engaged in interstate commerce.
Assess the applicability of the Federal Arbitration Act's Section 1 exemption to current employment contracts.
Consult legal counsel regarding potential litigation risks and contract modifications.

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March 9, 2026 Get Citation Alerts Download PDF Add Note

Kendal Bellard v. Henry A. Hollier, Nicolle Hollier and ABC Insurance Company

Louisiana Court of Appeal

Citations: None known
Docket Number: 2025 CW 1016
Precedential Status: Unknown Status
Opinion
Authorities (2)
Cited By (0)
Summaries (0)
Similar Cases (0)
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Combined Opinion

STATE OF LOUISIANA
COURT OF APPEAL, FIRST CIRCUIT

KENDAL BELLARD NO. 2025 CW 1016
VERSUS

HENRY A. HOLLIER, NICOLLE
HOLLIER, AND ABC INSURANCE

COMPANY MARCH 09, 2026

In Re: Kendal Bellard, applying for supervisory writs, 19th
Judicial District Court, Parish of East Baton Rouge,
No. 741660.

BEFORE : MILLER, EDWARDS, AND FIELDS, JJ.

WRIT GRANTED. The portion of the trial court's September
10, 2025 judgment which granted defendant’s, Amazon Logistics,
Inc., Exception of Prematurity is reversed. The Federal
Arbitration Act, 9 U.S.C. § 1, exempts employment contracts with
workers engaged in interstate commerce from the FAA. The United
States Supreme Court has stated “. . . while we did not provide
a complete definition of ‘transportation worker,’ we indicated
that any such worker must at least play a direct and ‘necessary
role in the free flow of goods’ across borders.” Sw. Airlines
Co. v. Saxon, 596 U.S. 450, 458, 142 S.Ct. 1783, 1790, 213
L.Ed.2d 27 (2022), citing Circuit City Stores, Inc. v. Adams,
932 U.S. 105, 121, 121 S.Ct. 1302, 1312, 149 L.Ed.2d 234 (2001).
Generally, there appears to be no dispute that plaintiff, Kendal
Bellard, delivered Amazon packages, which began within the flow
of interstate commerce. See Miller v. Amazon.com, Inc., No. 21-
36048, 2023 WL 5665771, (9th Cir. 2023). Accordingly, under the
Federal Arbitration Act, 9 U.S.C. § 1, the employment contract
of Kendal Bellard, as a transportation worker, is exempt from
arbitration. Therefore, the exception of prematurity filed by
defendant, Amazon Logistics, Inc., is denied.