We will hear argument this morning in case 24-935, Flowers, Foods v. Brock.

Ms. Lovett.

Thank you, Mr. Chief Justice, and may it please the Court.

In Beesonet and Saxon, this Court held that a Section 1 transportation worker must be actively engaged in transportation of goods across borders.

The class of workers must be directly and actively performing cross-border transportation work.

Brock picks up goods from a warehouse in Colorado and delivers them to retail outlets in Colorado.

When he takes the goods, they've crossed their last border,

and they have been unloaded from the interstate vehicle carrying them.

Mr. Brock performs no work in cross-border transportation and is not exempt under Section 1.

This result is faithful to Section 1's text and to this Court's precedent

because it focuses

the inquiry on the workers' connectivity to cross-border transportation work.

Brock's rule departs from text and precedent by focusing on the workers' relationship to a

good and the goods relationship to interstate commerce.

And Brock's approach would lead to unlimited chaos.

It is a world where everything is dispositive and everything is relevant and nothing is dispositive.

We know that because that's what's happening in the first, ninth and 10th circuits today, all of which follow Brock's approach.

And Brock's approach sweeps in too many workers into Section 1. Today, in the Ninth Circuit, workers who

deliver the New York Times in the state of California have been deemed Section 1 exempt workers by the Ninth Circuit

because the New York Times is printed in another state and arrives in California in boxes

from another state. Under that logic, the store clerk who unpacks boxes from another state

and transports them to the shelf should also be exempt.

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