Interlocutory Appeals, Arbitration, and Transportation-Worker CBAs: The Eleventh Circuit’s Jurisdictional Limits in APM Terminals Mobile, LLC v. ILA Local 1410

I. Introduction

The Eleventh Circuit’s decision in APM Terminals Mobile, LLC v. International Longshoremen's Association, AFL-CIO, Local Union 1410, No. 24‑11100 (11th Cir. Nov. 17, 2025), addresses a deceptively technical but practically important question: when, if ever, can a party immediately appeal a district court’s order denying a motion to compel arbitration under a collective bargaining agreement (CBA) covering transportation workers?

The core holding is jurisdictional: the Eleventh Circuit dismisses an interlocutory appeal for lack of appellate jurisdiction, rejecting three distinct theories advanced by the union:

• that the Federal Arbitration Act (FAA), specifically 9 U.S.C. § 16, authorizes an interlocutory appeal;
• that § 301 of the Labor Management Relations Act (LMRA), 29 U.S.C. § 185, somehow alters the usual finality requirements; and
• that the collateral-order doctrine permits immediate review of an order denying arbitration in this type of labor dispute.

The opinion is especially significant because the CBA here governs longshore workers at the Port of Mobile—workers whom the court treats as a “class of workers engaged in foreign or interstate commerce” within the meaning of the FAA’s § 1 “transportation worker” exclusion. That exclusion removes their “contracts of employment,” including CBAs, from the FAA’s coverage. Consequently, they cannot invoke § 16’s special interlocutory appeal provisions for orders denying arbitration.

The decision reinforces several key principles:

• CBAs are “contracts of employment” subject to the FAA’s § 1 exclusion when they cover transportation workers engaged in interstate or foreign commerce.
• The LMRA provides a substantive cause of action, not a special appellate-jurisdiction shortcut.
• The collateral-order doctrine remains “modest” and does not extend to orders denying arbitration, even in the labor-arbitration setting.

II. Factual and Procedural Background

A. The Parties and the Collective Bargaining Agreement

APM Terminals Mobile, LLC (“APM”) performs stevedoring operations at the Port of Mobile, Alabama, handling the loading and discharge of containerized cargo for interstate transportation. Local 1410 of the International Longshoremen's Association (the “Union”) represents the longshore workers who physically move that cargo.

Their relationship is governed by a collective bargaining agreement. Two provisions of that CBA are crucial:

• Article 4 (No-Strike / No-Lockout & Judicial Remedies) Article 4 contains a reciprocal no-strike / no-lockout clause:
  • APM agrees not to lock out union members.
  • Union members agree not to strike.
  It also expressly allows the parties to:
  • seek “equitable relief” immediately (e.g., injunctions) to remedy an alleged lockout or strike; and
  • institute “judicial or administrative action” for damages once certain conditions precedent are satisfied.
• Article 5 (Grievance and Arbitration Procedure) Article 5 provides that “[a]ll grievances or disputes arising from the application, interpretation or alleged violation” of the CBA “shall be settled” through a multi-step grievance procedure, culminating in arbitration.

B. The Alleged Strike and the Initial Litigation

While the CBA was in effect, APM alleged that union members commenced a strike in violation of Article 4. On the first day of the alleged strike, APM filed a complaint in Alabama state court and sought a temporary restraining order (TRO) to halt the work stoppage.

The state court quickly granted the TRO, and the strike ended within two days. Afterward:

• The Union removed the case to the federal district court in the Southern District of Alabama.
• APM amended its complaint to seek damages for the alleged strike, alleging that the Union’s conduct violated Article 4 and that all contractual conditions precedent to bringing a damages action had been satisfied.

At this point, the case was no longer just about emergency injunctive relief—it was a damages suit for alleged breach of the no-strike clause.

C. The Motion to Compel Arbitration

The Union then moved to compel arbitration, arguing that APM’s claim for damages was a “grievance or dispute” arising from the application or alleged violation of the CBA and thus had to be resolved under Article 5’s grievance-arbitration procedure.

The district court disagreed. It concluded that Article 4 explicitly allowed APM to pursue monetary damages “in court” once the contractual conditions precedent were met, and therefore denied the motion to compel arbitration. The merits action—APM’s damages suit—remained pending in the district court.

The Union filed an interlocutory appeal challenging the denial of arbitration, and APM moved to dismiss that appeal for lack of appellate jurisdiction. The Eleventh Circuit “carried” the motion with the case, meaning it would be resolved together with the appeal.

III. Summary of the Opinion

The Eleventh Circuit, in an opinion by Chief Judge William Pryor, does not address the merits of whether the CBA requires arbitration. Instead, it focuses entirely on whether the court of appeals has jurisdiction to hear the appeal at this stage.

The court holds:

1. No jurisdiction under the Federal Arbitration Act. Section 16 of the FAA, which authorizes interlocutory appeals from orders “denying a petition ... to order arbitration to proceed,” does not apply because:
   • Section 1 of the FAA excludes “contracts of employment of ... [a] class of workers engaged in foreign or interstate commerce.”
   • CBAs are “contracts of employment” under Eleventh Circuit precedent.
   • Longshore workers who load and unload cargo for interstate transportation are a “class of workers engaged in foreign or interstate commerce,” as confirmed by the Supreme Court’s approach in Southwest Airlines Co. v. Saxon.
   Thus, the entire FAA—including § 16’s appellate provision—does not apply.
2. No jurisdiction under LMRA § 301. Section 301 authorizes federal courts to create and apply federal common law to enforce CBAs, but it does not create any special right to interlocutory appeals. The union identifies no authority that § 301 alters the usual rule that appeals must await a final decision.
3. No jurisdiction under the collateral-order doctrine. The collateral-order doctrine allows immediate appeal only of a narrow category of decisions that:
   • conclusively resolve a disputed question,
   • address an important issue completely separate from the merits, and
   • would be effectively unreviewable after final judgment.
   The court holds that:
   • An erroneous denial of arbitration can be remedied on appeal from a final judgment (the case can be reversed and remanded for arbitration).
   • Supreme Court precedent tightly cabins the collateral-order doctrine, particularly in cases involving forum-selection and arbitration clauses.
   • The federal policy favoring labor arbitration and the existence of FAA § 16 do not transform denials of labor arbitration into collateral orders.

Because none of these asserted bases supports interlocutory jurisdiction, the Eleventh Circuit dismisses the appeal and expressly “express[es] no opinion on the merits” of the arbitration dispute.

IV. Detailed Analysis of the Court’s Reasoning

A. The Baseline: Final Decisions and Appellate Jurisdiction

The court starts with the basic jurisdictional rule under 28 U.S.C. § 1291: courts of appeals generally have jurisdiction only over “final decisions” of the district courts—those that “end[] the litigation on the merits and leave[] nothing more for the [district] court to do but execute the judgment,” as reiterated in SmileDirectClub, LLC v. Battle, 4 F.4th 1274, 1277–78 (11th Cir. 2021) (en banc).

Here, the order under review only does one thing: it requires the Union to defend APM’s damages claim in federal court rather than in arbitration. It does not:

• resolve whether the Union breached the no-strike clause;
• determine liability for damages; or
• enter any final judgment.

The litigation on the merits plainly has not ended. Thus, the order is non-final and not appealable under the general rule. The Union can proceed only if it fits within a statutory grant of interlocutory jurisdiction or the narrow collateral-order doctrine.

B. The Federal Arbitration Act Does Not Apply: Sections 1 and 16

1. Section 16’s Appeal Provisions

Section 16(a) of the FAA authorizes interlocutory appeals from certain orders, including orders “denying a petition ... to order arbitration to proceed,” 9 U.S.C. § 16(a)(1)(B). Ordinarily, an employer or union seeking to compel arbitration under a CBA might attempt to rely on § 16 for an immediate appeal of an adverse ruling.

But § 16 operates only for disputes governed by the FAA. The critical question is whether the CBA in this case falls within the FAA’s scope.

2. Section 1’s Transportation-Worker Exclusion

Section 1 of the FAA provides:

“... nothing herein contained shall apply to contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce.”

The Eleventh Circuit’s reasoning proceeds in two steps:

1. CBAs are “contracts of employment.” In American Postal Workers Union v. U.S. Postal Service, 823 F.2d 466, 473 (11th Cir. 1987), the court held that collective bargaining agreements qualify as “contracts of employment” for purposes of the § 1 exclusion. That longstanding precedent squarely covers the CBA between APM and Local 1410.
2. Longshore workers are a “class of workers engaged in foreign or interstate commerce.” The court relies heavily on the Supreme Court’s decision in Southwest Airlines Co. v. Saxon, 142 S. Ct. 1783 (2022). In Saxon, the Court held that workers who “physically load and unload cargo on and off airplanes on a frequent basis” are within § 1’s exclusion as a class of workers engaged in foreign or interstate commerce. The Eleventh Circuit finds “no material distinction” between:
   • the ramp supervisors in Saxon, who load and unload cargo from planes; and
   • the longshore workers here, who load and discharge containerized cargo at a port for interstate transportation.
   The Union itself acknowledges that it represents longshore employees who aid in loading and discharging containerized cargo at the Port of Mobile, which is part of the interstate and foreign commerce system.

Putting these two principles together:

• The CBA is a “contract of employment.”
• It covers a “class of workers engaged in foreign or interstate commerce.”

Therefore, § 1 excludes the CBA—and disputes arising under it—from the FAA’s coverage entirely.

3. Consequence: Section 16 Does Not Apply

Because § 1 excludes this CBA from the FAA, none of the FAA’s provisions, including § 16’s interlocutory appeal rights, apply to this dispute. The Union cannot rely on § 16 as a jurisdictional hook.

This is a crucial clarification: even if the type of order (denial of arbitration) is the very category § 16 ordinarily reaches, § 16 jurisdiction exists only when the FAA governs the agreement. For transportation workers excluded by § 1, the FAA—and thus § 16—simply does not operate.

C. LMRA § 301 Does Not Expand Appellate Jurisdiction

The Union next turned to § 301 of the LMRA, 29 U.S.C. § 185, which authorizes federal courts to fashion a body of federal law for the enforcement of CBAs. The Supreme Court’s landmark decision in Textile Workers Union v. Lincoln Mills of Alabama, 353 U.S. 448 (1957), confirmed that § 301 empowers courts to:

• enforce CBAs;
• compel arbitration pursuant to CBA arbitration clauses; and
• apply a federal substantive law of labor contracts.

However, as the Eleventh Circuit emphasizes, § 301 “says nothing about interlocutory appeals.” It is a grant of subject-matter jurisdiction and a directive to develop federal common law—it is not a distinct grant of appellate jurisdiction. The Union “fails to identify any authority” suggesting that § 301 modifies the “longstanding principles of finality” that govern under 28 U.S.C. § 1291.

The Union cited Goodall-Sanford, Inc. v. United Textile Workers, Local 1802, 353 U.S. 550 (1957), where the Supreme Court reviewed an order compelling arbitration under a CBA. But the Eleventh Circuit rightly distinguishes that case:

• In Goodall-Sanford, the only relief requested by the plaintiff was specific performance of the arbitration clause—that is, an order compelling arbitration. When the district court granted that relief, there was nothing further to decide; arbitration was the “full relief sought.” The order was, therefore, a final decision, appealable under § 1291.
• In contrast, APM has a damages action “still pending in the district court.” The order denying arbitration is a step along the way, not a final resolution. The Eleventh Circuit has previously held that orders concerning arbitration are not “final” in this situation. See ConArt, Inc. v. Hellmuth, Obata + Kassabaum, Inc., 504 F.3d 1208, 1209–10 (11th Cir. 2007).

Thus, § 301 provides the substantive framework for resolving CBA disputes but does not create a special appellate route for interlocutory review of orders granting or denying arbitration when the merits remain unresolved.

D. The Collateral-Order Doctrine and Arbitration Denials

1. The Three Requirements

The collateral-order doctrine, derived from Cohen v. Beneficial Industrial Loan Corp., allows review of a “small class” of non-final orders that:

1. conclusively determine the disputed question;
2. resolve an important issue completely separate from the merits; and

would be effectively unreviewable on appeal from a final judgment.

The Eleventh Circuit follows its en banc decision in SmileDirectClub, which stresses that:

• these criteria are applied to “the entire category to which [an order] belongs,” not case-by-case idiosyncrasies; and
• parties seeking review under the doctrine face a “high bar.”

2. Prior Eleventh Circuit Arbitration Precedent

The court notes that it has “so held decades ago” that denials of motions to compel arbitration are not collateral orders. In Administrative Management Services, Ltd. v. Royal American Managers, Inc., 854 F.2d 1272, 1277–78 (11th Cir. 1988), the court explained:

An erroneous denial of arbitration “may be reversed on appeal from the final judgment of the underlying claim ... and remanded for arbitration.”

That reasoning addresses the third prong—effective unreviewability—head-on: if an error can be remedied after final judgment, the order is not “effectively unreviewable” and cannot qualify as a collateral order.

The court reached a similar conclusion in ConArt, this time in the mirror-image context of an order refusing to enjoin arbitration: an order declining to halt an arbitration “can be reviewed after final judgment is entered in the case following the conclusion of arbitration.” 504 F.3d at 1211.

3. Supreme Court Narrowing: Forum-Selection and Arbitration Clauses

The Eleventh Circuit places its own precedent within a broader Supreme Court trend limiting the collateral-order doctrine.

• In Will v. Hallock, 546 U.S. 345, 350 (2006), the Court described the doctrine as “modest in scope,” citing Digital Equipment Corp. v. Desktop Direct, Inc., 511 U.S. 863, 868 (1994).
• In Lauro Lines s.r.l. v. Chasser, 490 U.S. 495 (1989), the Court held that denials of motions to dismiss based on a contractual forum-selection clause are not immediately appealable under the collateral-order doctrine, even though such clauses confer important rights.
• In Vimar Seguros y Reaseguros, S.A. v. M/V Sky Reefer, 515 U.S. 528, 534 (1995), the Court observed that “arbitration clauses are but a subset of ... forum-selection clauses.” This strongly suggests that if forum-selection clauses do not generally qualify for collateral-order treatment, arbitration clauses typically will not either.

Taken together, these authorities support the Eleventh Circuit’s conclusion: the fact that an order affects the forum (court vs. arbitration) does not, by itself, justify immediate appeal under the collateral-order doctrine.

4. The “Federal Policy Favoring Arbitration” in Labor Law

The Union urged that the strong federal policy in favor of labor arbitration and “industrial peace” justifies application of the collateral-order doctrine. The court acknowledges that federal labor law encourages arbitration but notes two critical limits:

• As the Supreme Court stated in Granite Rock Co. v. International Brotherhood of Teamsters, 561 U.S. 287, 300, 302 (2010), even in labor disputes, arbitration cannot occur unless the parties have actually agreed to arbitrate; arbitration remains a matter of contract.
• Private arbitration agreements “are [not] likely ... to supply the basis of a collateral order appeal.” Acheron Capital, Ltd. v. Mukamal, 22 F.4th 979, 990 (11th Cir. 2022).

The truly “crucial question,” under Mohawk Industries, Inc. v. Carpenter, 558 U.S. 100, 108 (2009), is whether deferring review until final judgment “so imperils” the interest at stake as to justify the systemic costs of allowing immediate appeals in every such case. The Eleventh Circuit concludes that it does not.

5. Alternative Avenues to Protect Labor Interests

The court also points out that other tools exist to protect the very interests the Union invokes—quick relief and industrial peace. For instance:

• Temporary restraining orders and preliminary injunctions under Federal Rule of Civil Procedure 65 can provide immediate relief to preserve the status quo during a labor dispute.
• Indeed, in this case, the TRO obtained by APM in state court ended the strike within days, long before arbitration was even requested.

Because injuries to labor peace and contractual rights can be mitigated or addressed through such mechanisms and because any erroneous denial of arbitration can be corrected after final judgment, the Union cannot satisfy the “effectively unreviewable” requirement for collateral-order appeals.

6. FAA § 16 Does Not “Supersede” the Collateral-Order Analysis

The Union also argued that Congress effectively superseded the Eleventh Circuit’s earlier holding in Administrative Management Services by enacting § 16 of the FAA, which provides for interlocutory appeals from certain arbitration-related orders. The court rejects that contention for two reasons:

1. Section 16 does not govern this case. Because of § 1’s exclusion, the FAA does not apply to this CBA. A statute that does not apply cannot supply jurisdiction or alter the collateral-order analysis.
2. Even when § 16 does apply, it does not transform orders into “collateral orders.” Congress can create specific statutory rights to interlocutory appeals (as it did in § 16), but that does not mean those orders would otherwise meet the “stringent” collateral-order criteria. The Eleventh Circuit underscores that nothing in § 16 displaces its prior holding that erroneous denials of arbitration remain adequately reviewable after final judgment. See Digital Equipment, 511 U.S. at 868 (describing those criteria as “stringent”).

Therefore, even in FAA-covered cases, § 16 reflects a policy choice by Congress to allow immediate appeals; it does not rest on a constitutional or doctrinal conclusion that such orders are inherently “effectively unreviewable.” In FAA-exempt labor disputes, where § 16 does not apply, courts return to the default rule: no collateral-order interlocutory appeal from arbitration denials.

V. Precedents Cited and Their Influence

The opinion weaves together a substantial body of Supreme Court and Eleventh Circuit precedent. Some of the most important are:

• American Postal Workers Union v. U.S. Postal Service, 823 F.2d 466 (11th Cir. 1987) Held that CBAs are “contracts of employment” for purposes of FAA § 1. This is the key step that brings the CBA within the transportation-worker exclusion.
• Southwest Airlines Co. v. Saxon, 142 S. Ct. 1783 (2022) Clarified the scope of the “class of workers engaged in foreign or interstate commerce” for § 1, holding that ramp supervisors who frequently load and unload cargo on planes are within the exclusion. The Eleventh Circuit extends that reasoning to longshore workers who load/unload containerized cargo at a port.
• Textile Workers Union v. Lincoln Mills of Alabama, 353 U.S. 448 (1957) Established that § 301 LMRA authorizes federal courts to enforce CBAs and compel arbitration, but did not address or alter finality rules for appeals.
• Goodall-Sanford, Inc. v. United Textile Workers, Local 1802, 353 U.S. 550 (1957) Addressed the appealability of an order directing arbitration. The Supreme Court treated it as a final judgment because arbitration was the full relief requested. The Eleventh Circuit distinguishes this case because APM’s damages action remains pending, so the order denying arbitration was not final.
• Administrative Management Services, Ltd. v. Royal American Managers, Inc., 854 F.2d 1272 (11th Cir. 1988) Held that denials of arbitration are not collateral orders, emphasizing that such errors can be corrected on appeal after final judgment.
• ConArt, Inc. v. Hellmuth, Obata + Kassabaum, Inc., 504 F.3d 1208 (11th Cir. 2007) Confirmed that orders involving arbitration are not “final” when substantive claims remain pending. Also held that orders refusing to enjoin arbitration are reviewable after final judgment, reinforcing the non-collateral nature of arbitration-related orders.
• SmileDirectClub, LLC v. Battle, 4 F.4th 1274 (11th Cir. 2021) (en banc) Clarified the meaning of final decisions and stressed that the collateral-order doctrine applies to “categories” of orders, not idiosyncratic case-specific concerns.
• Acheron Capital, Ltd. v. Mukamal, 22 F.4th 979 (11th Cir. 2022) Emphasized that litigants seeking collateral-order review face a “high bar” and observed that private agreements are poor candidates for collateral-order treatment.
• Lauro Lines s.r.l. v. Chasser, 490 U.S. 495 (1989) Rejected collateral-order appeals from denials of motions invoking forum-selection clauses, laying groundwork for the parallel treatment of arbitration clauses as non-collateral.
• Vimar Seguros y Reaseguros, S.A. v. M/V Sky Reefer, 515 U.S. 528 (1995) Described arbitration clauses as a subset of forum-selection clauses, aligning arbitration with other forum-selection mechanisms for jurisdictional purposes.
• Will v. Hallock, 546 U.S. 345 (2006) and Digital Equipment Corp. v. Desktop Direct, Inc., 511 U.S. 863 (1994) Reiterated that the collateral-order doctrine has a “modest” scope and “stringent” requirements.
• Granite Rock Co. v. International Brotherhood of Teamsters, 561 U.S. 287 (2010) Emphasized that arbitration in labor disputes, as elsewhere, arises from agreement; labor policy favoring arbitration does not override the need for actual consent.
• Mohawk Industries, Inc. v. Carpenter, 558 U.S. 100 (2009) Clarified that the key question for the collateral-order doctrine is whether deferring appellate review genuinely renders an important right effectively unreviewable.
• United Steel Workers International Union v. Wise Alloys, LLC, 642 F.3d 1344 (11th Cir. 2011) Noted that courts may “borrow” rules from the FAA when existing law is silent, but only where the FAA applies. Here, by contrast, § 1 excludes the agreement.
• Finn v. Cobb County Board of Elections & Registration, 111 F.4th 1312 (11th Cir. 2024) Stands for the principle that when jurisdiction is lacking, courts must refrain from expressing any view on the merits—a principle the court follows here.

VI. Complex Concepts Explained in Plain Terms

A. “Final Decision” and “Interlocutory Appeal”

A final decision is one that resolves all issues in the case and leaves nothing for the court to do except execute the judgment. By contrast, many orders issued during a case—like discovery rulings, partial summary judgment, or, as here, denial of arbitration—are interlocutory: they occur in the middle of the litigation.

As a general rule, appeals must await a final decision to avoid piecemeal litigation and frequent disruption of trial-court proceedings.

B. The Collateral-Order Doctrine

The collateral-order doctrine is a narrow exception. It allows immediate appeal of a small category of orders that:

• conclusively decide an issue;
• address an important issue separate from the merits of the case; and
• would be impossible (or practically impossible) to review effectively after final judgment.

Classic examples include:

• denials of absolute or qualified immunity (where the immunity is an immunity from trial itself);
• denials of double jeopardy claims in criminal cases; and
• some orders compelling disclosure of highly sensitive or privileged information in limited contexts.

By contrast, orders that can be corrected later—for example, by reversing a judgment and ordering arbitration—usually do not qualify.

C. The FAA Transportation-Worker Exclusion

The FAA generally makes arbitration agreements “valid, irrevocable, and enforceable.” But § 1 excludes “contracts of employment of ... any other class of workers engaged in foreign or interstate commerce.” The Supreme Court and courts of appeals have interpreted this exclusion to cover transportation workers such as:

• seamen;
• railroad employees; and
• others who are actively engaged in transporting goods or passengers across state or national borders.

Saxon clarified that workers who load and unload cargo onto aircraft—an integral part of the interstate transportation process—are covered. Longshore workers who load and discharge containerized cargo at a seaport occupy a similar role in the logistics chain.

D. Collective Bargaining Agreements and LMRA § 301

A collective bargaining agreement (CBA) is a contract between an employer (or group of employers) and a labor union that governs wages, hours, working conditions, dispute resolution, and more. Section 301 of the LMRA authorizes lawsuits in federal court for violations of CBAs and instructs courts to fashion a federal common law of labor contracts.

CBAs often contain:

• no-strike clauses (union promises not to strike under certain circumstances);
• no-lockout clauses (employer promises not to lock out workers); and
• grievance and arbitration procedures for resolving disputes about the interpretation or application of the agreement.

While § 301 allows courts to enforce these provisions and order arbitration, it does not itself say anything about when appeals can be taken. That is controlled by the usual finality rules and any specific appellate statutes.

E. Forum-Selection and Arbitration Clauses

A forum-selection clause is a contract provision specifying where disputes will be litigated (e.g., “all disputes shall be brought in New York courts”). An arbitration clause is a specific kind of forum-selection clause in which the parties agree to resolve disputes in arbitration instead of court.

The Supreme Court has treated arbitration clauses as a subset of forum-selection clauses. Denials of motions to enforce such clauses usually are not immediately appealable under the collateral-order doctrine because:

• the underlying dispute can still be litigated; and
• if the court erred, an appellate court can correct that error later, even if some “litigation costs” have been incurred in the meantime.

F. Temporary Restraining Orders and Preliminary Injunctions

A temporary restraining order (TRO) is an emergency order intended to preserve the status quo for a short period, often issued very quickly, sometimes without full adversarial briefing.

A preliminary injunction is similar but usually follows more formal procedures and can remain in place longer while the case proceeds. Both are governed by Federal Rule of Civil Procedure 65 (or analogous state rules).

In the labor context, TROs or preliminary injunctions can quickly halt strikes or other disruptive conduct while contractual or legal disputes are worked out—one reason the Eleventh Circuit finds that industrial peace does not require special appellate rules for arbitration denials.

VII. Impact and Practical Implications

A. For Transportation-Sector CBAs in the Eleventh Circuit

The decision has concrete implications for employers and unions in transportation industries within the Eleventh Circuit (Alabama, Florida, Georgia):

• No FAA-based interlocutory appeal for transportation-worker CBAs. Where a CBA covers workers who are part of the interstate or foreign transportation of goods (such as longshore workers, seaport workers, or similar cargo handlers), the FAA’s § 1 exclusion will likely apply. That means:
  • § 16’s special right to immediate appeal from orders denying arbitration does not apply.
  • Parties must generally wait for a final judgment before appealing a denial of arbitration.
• LMRA § 301 does not override finality rules. Parties cannot use § 301 as a jurisdictional shortcut to obtain early appellate review of arbitration-related orders that do not end the case.
• Collateral-order doctrine remains closed to arbitration denials. Efforts to repackage arbitration disputes as “important, separate” issues suitable for collateral-order treatment are unlikely to succeed, even when framed in terms of labor policy or industrial peace.

B. Strategic Considerations in Labor Litigation

Unions and employers must adjust their litigation strategies accordingly:

• If a district court erroneously denies arbitration, the aggrieved party will usually need to:
  • litigate the case through to a final judgment (or at least to a dispositive ruling on all claims); and then
  • argue on appeal that the case should have been sent to arbitration from the outset, seeking reversal and remand for arbitration.
• If immediate relief is needed to halt a strike, lockout, or other disruption, the appropriate tool is:
  • a TRO or preliminary injunction, not an emergency appeal on arbitrability.
• Settlement dynamics may be affected: a party denied arbitration may be less able to delay or fragment the litigation by pursuing an interlocutory appeal.

C. Doctrinal Reinforcement and Predictability

From a doctrinal standpoint, the decision reinforces several clear rules within the Eleventh Circuit:

• CBAs covering transportation workers are exempt from the FAA under § 1.
• Arbitration-related orders in such cases are governed by general finality rules, not by § 16.
• The collateral-order doctrine remains a narrow exception, consistent with Supreme Court guidance, and does not extend to arbitration denials (or refusals to enjoin arbitration).

This clarity promotes predictable appellate practice and discourages attempts to stretch the collateral-order doctrine to cover private contractual disputes about forum, even where labor policy strongly favors arbitration.

VIII. Conclusion

APM Terminals Mobile, LLC v. ILA Local 1410 does not resolve whether the parties must arbitrate their dispute over the alleged strike; the Eleventh Circuit explicitly declines to reach that issue. Instead, the case is a carefully reasoned reaffirmation of jurisdictional principles in the arbitration-labor nexus.

The key takeaways are:

• CBAs governing longshore and similar transportation workers fall within the FAA’s § 1 exclusion as “contracts of employment” of a “class of workers engaged in foreign or interstate commerce.”
• Because of that exclusion, 9 U.S.C. § 16’s provision for interlocutory appeals from orders denying arbitration does not apply to such agreements.
• Section 301 of the LMRA supplies substantive law and subject-matter jurisdiction for CBA disputes but does not relax the final-judgment rule for appeals.
• The collateral-order doctrine, as constrained by Supreme Court and Eleventh Circuit precedent, does not permit immediate appeal from arbitration denials, even in labor disputes and even in light of federal policies favoring arbitration.

For practitioners, the lesson is straightforward: in transportation-worker CBA disputes within the Eleventh Circuit, challenges to district court rulings on arbitrability almost never qualify for interlocutory review. Barring an independent statutory grant of appellate jurisdiction, parties must either seek prompt trial-court remedies (like TROs and preliminary injunctions) or preserve their arbitration arguments for appeal from a final judgment.

As a result, APM Terminals Mobile stands as an important precedent at the intersection of labor law, arbitration law, and appellate procedure, marking the Eleventh Circuit’s firm commitment to traditional finality principles even in the face of modern pro-arbitration and pro-labor-arbitration policies.