Abdisalam v. Strategic Delivery Solutions, LLC

── Abdisalam v. Strategic Delivery Solutions, LLC ── Case No.: 25-1254 Court: Court of Appeals for the First Circuit Date: March 17, 2026 Category: General United States Court of Appeals For the First Circuit No. 25-1254 ABDULKADIR ABDISALAM, individually and for all others similarly situated, Plaintiff, Appellee, v. STRATEGIC DELIVERY SOLUTIONS, LLC, Defendant, Appellant. APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS [Hon. Richard G. Stearns, U.S. District Judge] Before Barron, Chief Judge, Kayatta and Rikelman, Circuit Judges. James A. Eckhart, with whom Andrew J. Butcher and Scopelitis, Garvin, Light, Hanson & Feary, P.C. were on brief, for appellant. Brant Casavant, with whom Brook Lane and Fair Work P.C. were on brief, for appellee. March 17, 2026  RIKELMAN, Circuit Judge. For several years, Abdulkadir Abdisalam provided courier services for Strategic Delivery Solutions, LLC ("SDS"), a healthcare delivery company. Eventually, he sued SDS, alleging that it misclassified its couriers as independent contractors and failed to pay them appropriate wages, all in violation of Massachusetts law. In response, SDS filed a motion to stay the case and compel arbitration of Abdisalam's claims. SDS pointed to an arbitration provision in an agreement between it and Abdul Courier, LLC, a corporation that SDS had required Abdisalam to form in order to provide it with courier services. The district court determined that Abdisalam was not a signatory to that agreement and could not be bound by its arbitration provision as a matter of contract law or under principles of equitable estoppel; it then denied SDS's motion. We agree with the district court's ruling and thus affirm. I. BACKGROUND A. Relevant Facts SDS transports medication and medical supplies for pharmacies, hospitals, and laboratories and operates in several states, including Massachusetts.1 To provide these healthcare delivery services, SDS retains individuals to act as couriers. 1 We draw the relevant facts from the operative complaint and the parties' submissions related to SDS's motion to compel arbitration. See Cullinane v. Uber Techs., Inc., 893 F.3d 53, 55 (1st Cir. 2018). - 2 - But SDS does not hire the couriers directly; instead, it requires prospective couriers to form "their own corporations" and then contracts with those corporations to provide courier services for SDS. SDS classifies its couriers as independent contractors, rather than employees. Consistent with its usual practice, SDS required Abdisalam to form his own corporation before he could provide deliveries for the company.2 So, Abdisalam created Abdul Courier, LLC, which he registered with the Secretary of the Commonwealth of Massachusetts. Abdul Courier, LLC and SDS entered into an Independent Vendor Agreement for Transportation Services (the "Vendor Agreement") in April 2019. The Vendor Agreement is a form contract that SDS prepared; neither Abdul Courier, LLC nor Abdisalam drafted or negotiated any portion of it. Abdisalam signed the Vendor Agreement as the "Owner" of Abdul Courier, LLC. In its first sentence, the Vendor Agreement states that it was "entered into . . . by and between ABDUL COURIER LLC . . . (the 'Vendor') and Strategic Deliver