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Wednesday, May 20, 2026

ARBITRATION—1st Cir.: Court declines compulsory arbitration of wage claims under agreement with courier’s LLC - VitalLaw.com

Strategic Delivery Solutions required the courier to form his own corporation before he could provide deliveries for it.

Strategic Delivery Solutions, LLC was not entitled to compel arbitration of a courier’s suit alleging that the company misclassified its couriers as independent contractors and failed to pay them appropriate wages under Massachusetts law, despite his own limited liability corporation’s arbitration agreement with the healthcare delivery company, the First Circuit affirmed. Because the courier himself was not a signatory to his LLC’s vendor agreement with Strategic Delivery Solutions, the agreement's terms, including its arbitration provision, did not bind him in his personal capacity. The court also rejected the delivery company’s alternative direct benefits estoppel, intertwined claims estoppel, and successor-in-interest theories in support of its argument that the courier was personally bound to the arbitration provision (Abdisalam v. Strategic Delivery Solutions, LLC, No. 25-1254 (1st Cir. Mar. 17, 2026)).

Medical supplies. Strategic Delivery Solutions, LLC (SDS) transports medication and medical supplies for pharmacies, hospitals, and laboratories and operates in several states, including Massachusetts. To provide these healthcare delivery services, SDS retains individuals to act as couriers.

Contracts with couriers’ corporations. SDS does not hire its couriers directly, however. Instead, it requires prospective couriers to form "their own...



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