A May 2026 U.S. Supreme Court decision could have important implications for people injured in trucking crashes involving freight brokers and the carriers they select.
In Montgomery v. Caribe Transport II, LLC, the U.S. Supreme Court unanimously held that federal law, specifically the Federal Aviation Administration Authorization Act (FAAAA), does not preempt state-law claims alleging that a freight broker negligently hired or selected an unsafe motor carrier.
The decision addresses an important question in trucking litigation:
Can an injured person bring a state-law negligent hiring or negligent selection claim against a freight broker that selected the trucking company involved in a crash?
The Supreme Court’s answer is yes.
What Is a Freight Broker?
Freight brokers play an important role in the transportation industry. Rather than transporting goods themselves, brokers connect companies that need to ship goods with motor carriers that transport those goods.
The Supreme Court described brokers as essentially connecting sellers of goods with the carriers that move those goods. According to the Supreme Court, roughly 28,000 brokers arrange transportation for about one-third of all freight shipped in the United States.
That means a broker’s decision about which carrier to hire can be an important part of the transportation process.
What Happened in Montgomery v. Caribe Transport?
The case arose from a serious trucking collision in Illinois.
Shawn Montgomery was in his tractor-trailer when it was struck by a truck driven by Yosniel Varela-Mojena. Varela-Mojena was transporting a load for Caribe Transport II, LLC, and C.H. Robinson Worldwide, Inc. had coordinated the shipment as the freight broker.
Montgomery suffered severe and permanent injuries, including the amputation of his leg. He sued the truck driver, the motor carrier, and C.H. Robinson, among others. He alleged that C.H. Robinson negligently hired the driver and motor carrier.
Montgomery alleged that Caribe Transport had a “conditional” safety rating from the Federal Motor Carrier Safety Administration when C.H. Robinson selected the company. According to the allegations, the safety concerns included issues involving driver qualifications, hours of service, inspection, repair and maintenance, and crash rates.
The lower courts dismissed the negligent-hiring claim against C.H. Robinson based on federal preemption.
The case ultimately reached the U.S. Supreme Court.
Why Was Federal Preemption an Issue?
The dispute centered on the Federal Aviation Administration Authorization Act, or FAAAA.
Despite its name, the FAAAA contains provisions governing interstate trucking. Among other things, the law broadly preempts certain state laws related to the “price, route, or service” of motor carriers and freight brokers. 49 U.S.C. § 14501(c)(1).
Freight brokers argued that a negligent-hiring claim was preempted because it related to the broker’s transportation services.
But the FAAAA also contains an important safety exception. That exception states that federal preemption does not restrict a state’s “safety regulatory authority … with respect to motor vehicles.” 49 U.S.C. § 14501(c)(2)(A).
The Supreme Court had to determine whether a state-law negligent-hiring claim against a freight broker falls within that safety exception.
What Did the Supreme Court Decide?
The Supreme Court unanimously concluded a state-law negligent-hiring claim falls within the safety exception.
Writing for the Court, Justice Barrett explained that negligent-hiring claims impose a duty of reasonable care when selecting someone to perform work that carries a risk of physical harm. The Court determined that requiring a freight broker to exercise reasonable care when selecting a motor carrier concerns the motor vehicles that will be used to transport the goods. As a result, the safety exception applies.
The Court reversed the Seventh Circuit’s decision and sent the case back for further proceedings.
The Seventh Circuit subsequently vacated the judgment against Montgomery on his negligent-hiring claims and remanded the case to the federal district court for further proceedings.
What Does the Decision Mean for Trucking Accident Claims?
The decision does not mean that freight brokers are automatically responsible whenever a truck they helped arrange is involved in a crash.
Instead, Montgomery confirms that federal preemption does not prevent an injured person from pursuing a state-law negligent-hiring claim against a freight broker based on the broker’s selection of a motor carrier.
That distinction is important.
A trucking accident investigation may involve more than determining who was behind the wheel. Depending on the circumstances, it may also be important to understand:
- Who selected the motor carrier?
- What information did the broker have about the carrier?
- What was the carrier’s safety history?
- Were there concerns involving driver qualifications or safety compliance?
- What due diligence did the broker perform before selecting the carrier?
- Did the broker have information that could have raised concerns about the carrier’s ability to safely transport the shipment?
The answers to those questions will depend on the facts and evidence in each individual case.
The Decision Does Not Eliminate Federal Preemption
The Supreme Court’s decision should not be read as eliminating the FAAAA’s preemption protections.
The Court specifically explained that the safety exception applies to a subset of claims involving motor vehicle safety. State laws concerning motor carrier prices, routes, or services that have no relationship to safety remain subject to federal preemption.
In other words, Montgomery is specifically about the intersection of federal preemption, motor vehicle safety, and negligent hiring.
It does not create automatic liability for freight brokers, and it does not mean every state-law claim involving a broker can proceed.
Why This Matters After a Trucking Crash
Trucking accident cases can involve more than the driver who was behind the wheel. Depending on the circumstances, the investigation may need to examine the trucking company, freight broker, driver qualifications, safety history, and the decisions made before a truck ever took the road.
The Montgomery v. Caribe Transport decision makes clear that, at least as a matter of federal preemption, a freight broker cannot automatically rely on the FAAAA to shield itself from a state-law negligent-hiring claim involving the safety of the motor carrier it selected.
That can be particularly important in serious trucking cases where questions arise about how a carrier was selected and what the broker knew about that carrier’s safety history.
How Monsees & Mayer Approaches Trucking Accident Cases
At Monsees & Mayer, we understand that a serious trucking collision can require looking beyond the immediate circumstances of the crash.
Our attorneys investigate the evidence surrounding a collision to understand what happened, who was involved, and what factors may have contributed to the injuries. In cases involving commercial trucks, that can include examining driver qualifications, company records, safety information, vehicle evidence, and the relationships between the companies involved in transporting a shipment.
The U.S. Supreme Court’s decision in Montgomery v. Caribe Transport provides another important consideration when evaluating the potential role of a freight broker in a trucking accident case.
It does not mean a freight broker is automatically responsible for a crash. Instead, it confirms that federal law does not categorically prevent an injured person from pursuing a state-law negligent-hiring claim against a broker when the claim concerns motor vehicle safety.
If you or someone you love has been seriously injured in a trucking accident, Monsees & Mayer can help investigate the circumstances of the collision and evaluate the legal options available.
