The U.S. Supreme Court on May 14 ruled that federal law does not shield freight brokers from state-law negligence claims when they hire unsafe motor carriers, a decision that could expand liability exposure for companies that arrange trucking services.
In a unanimous decision in Montgomery v. Caribe Transport II, LLC, the court held that the Federal Aviation Administration Authorization Act’s (FAAAA) “safety exception” preserves states’ authority to allow lawsuits alleging that brokers negligently selected dangerous carriers. The ruling reverses a 7th Circuit decision that had barred such claims as preempted by federal law.
The case arose from a serious highway accident in Illinois. Plaintiff Shawn Montgomery was severely injured when his tractor-trailer, which was stopped on the shoulder, was struck by another truck operated by Caribe Transport II, LLC.
Montgomery sued multiple defendants, including C.H. Robinson Worldwide, one of the nation’s largest transportation brokers. He alleged that C.H. Robinson negligently hired Caribe Transport despite publicly available safety data indicating that the carrier posed an unreasonable risk.
C.H. Robinson argued that the FAAAA preempted the claim. The statute broadly bars states from enforcing laws “related to a price, route, or service of any motor carrier or broker.” According to the broker, allowing state negligence suits would interfere with how brokers perform their core service of selecting carriers.
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