Doss v. Tesla, Inc. (2026) — Cal.App.5th —, A173210
Key Takeaway: The First District Court of Appeal held that Tesla’s yard hostlers — workers who move 53-foot trailers containing auto parts around Tesla’s Fremont factory grounds — are transportation workers engaged in interstate commerce under Section 1 of the Federal Arbitration Act, even though they never leave the factory premises. The decision extends the FAA exemption to workers whose physical work is confined to a single site but whose role is integral to the interstate supply chain.
What Happened in Doss v. Tesla
Kenneth Doss worked as a yard hostler at Tesla’s Fremont factory between 2017 and 2021. His job was to use tractor trucks to move, position, and park 53-foot trailers within Tesla’s truck yard to facilitate shipping and receiving functions. The trailers contained auto parts shipped from out of state — including battery components from Nevada — that Tesla used to manufacture its vehicles. Doss could see the out-of-state addresses on shipping labels.
Doss filed a putative class action against Tesla for wage-and-hour violations, including overtime, meal and rest period, wage statement, and business expense reimbursement claims. Tesla moved to compel arbitration under an agreement Doss had signed as a condition of employment. The agreement included a class action waiver.
The trial court denied Tesla’s motion in its entirety. It found that the FAA did not apply because Doss was a transportation worker under Section 1, that California Labor Code section 229 rendered the agreement ineffective as to most claims, that the class waiver was unenforceable under the Gentry test, and that severance was inappropriate.
The First District affirmed the finding that Doss is a transportation worker exempt from the FAA. The court applied the Supreme Court’s framework from Southwest Airlines Co. v. Saxon (2022), which asks whether the worker belongs to a class of workers who are actually engaged in the movement of goods in interstate commerce.
Tesla’s yard hostlers, the court found, play an essential role in completing the interstate journey of auto parts: they move trailers from where they arrive to the docks where they are unloaded, and they position empty trailers for outbound shipments. Without the hostlers, the parts would not reach their final destination inside the factory.
The court rejected Tesla’s argument that because the hostlers never left factory grounds, they could not be engaged in interstate commerce. The interstate journey of the parts did not end at the factory gate. It ended when the parts were actually received and unloaded — and the hostlers were the workers who made that final step happen.
How the FAA Exemption Applies to Workers Who Never Leave a Single Worksite
Before Doss, it was generally understood that the Section 1 exemption applied to workers who physically transported goods across state lines or between locations. Doss extends the exemption to workers whose role in the interstate supply chain is performed entirely within the confines of a single facility — as long as their actual work involves handling goods that are in the course of an interstate journey.
The key is the Supreme Court’s test from Saxon: courts look at the actual work the employee performs, not the employer’s description of the role. Tesla characterized its hostlers as manufacturing support workers who happened to move trailers. The court looked at what they actually did: they drove trucks, moved 53-foot interstate shipping trailers, and facilitated the receipt and shipment of goods that had crossed state lines. That work, the court concluded, is transportation work.
The court also noted the etymological connection between yard hostlers and railroad hostlers — workers who traditionally moved locomotives in and out of rail yards. That analogy reinforced the conclusion that yard hostlers share the attributes of the transportation workers enumerated in Section 1.
What This Means for California Factory and Warehouse Workers
Doss is one of the most expansive applications of the Section 1 exemption in California so far. The court was careful to limit its holding to the specific facts — workers moving 53-foot interstate shipping trailers as their primary job function — and to distinguish hypothetical cases involving mailroom workers or people who simply pick up a package from a doorstep. But the reasoning opens a potentially significant door for workers at factories, distribution centers, and logistics hubs whose work touches goods in interstate transit.
For workers, the decision reinforces the trend in recent case law — including Saxon, Betanco v. Living Spaces, and Flowers Foods v. Brock — toward a functional analysis of what the worker actually does rather than where they do it or what the employer calls their role.
How to Know If You May Be Exempt from the FAA as a Transportation Worker
- You work at a warehouse, distribution center, factory, or logistics facility and your job involves physically handling, moving, delivering, or positioning shipping containers, trailers, or pallets that contain goods shipped from out of state.
- You drive tractors, forklifts, or trucks to move trailers or containers around a yard or facility, even if you never leave the premises.
- The goods you handle bear out-of-state shipping labels or originate from locations outside California.
- You signed an arbitration agreement as a condition of employment and were not given a meaningful opportunity to negotiate its terms.
- Your employer describes your role as manufacturing support, warehouse operations, or logistics but your actual day-to-day work involves moving goods that traveled interstate.
Talk to a Worker’s Rights Employment Attorney
If you work at a California warehouse, factory, or distribution center and have questions about whether your arbitration agreement is enforceable, King & Siegel LLP can evaluate your situation. The firm represents employees in wage-and-hour claims, arbitration disputes, and class actions. Consultations are free and confidential.
Julian Burns King graduated with honors from Harvard Law School and founded King & Siegel in 2018. As head of the Firm’s discrimination and harassment practice areas, she champions the rights of working parents and victims of workplace discrimination and harassment. She has been recognized as a “Rising Star” by Super Lawyers annually since 2018 and has recovered tens of millions of dollars on behalf of her clients.