Supreme Court Rules Unanimously: Freight Brokers Face State Negligent-Hiring Claims
In a unanimous 9-0 decision, the U.S. Supreme Court ruled that state negligent-hiring claims against freight brokers are not preempted by the Federal Aviation Administration Authorization Act (FAAAA), allowing lawsuits to proceed over injuries caused by carriers brokers select.
Case Background: Montgomery v. Caribe Transport II, LLC
The ruling stems from Montgomery v. Caribe Transport II, LLC, where truck driver Shawn Montgomery sued freight broker C.H. Robinson Worldwide, Inc., and motor carrier Caribe Transport II, LLC. Montgomery alleged that C.H. Robinson negligently hired Caribe Transport and its driver, Pedro Varela-Mojena, who caused an accident in Illinois that injured Montgomery while transporting plastic materials.
The case reached the Supreme Court after lower courts grappled with whether the FAAAA preempts such state tort claims. Justice Amy Coney Barrett authored the opinion, affirming that the FAAAA’s safety exception—under 49 U.S.C. § 14501(c)(2)(A)—preserves states’ authority to regulate motor vehicle safety.
Key Ruling Details
The Court held that requiring brokers to exercise ordinary care in selecting carriers “concerns motor vehicles—most obviously, the trucks that will transport the goods.” This places negligent-hiring claims within the safety exception, rejecting arguments from the trucking industry and the U.S. government that the law would invite excessive litigation.
Freight brokers arrange approximately one-third of U.S. freight shipments, making the decision significant for the industry. There are about 28,000 registered brokers, now potentially subject to state-level personal injury lawsuits for hiring unsafe carriers.
Industry Implications
The ruling reverses prior decisions that shielded brokers from such liability, enabling cases like Montgomery’s to advance in lower courts. It clarifies the balance between federal economic deregulation under the FAAAA and state powers over trucking safety, without imposing new federal mandates.