Supreme Court Holds Freight Brokers Liable for Negligent Hiring Decisions

Key Details The U.S. Supreme Court issued a unanimous ruling on May 14 that freight brokers can face state-level negligence lawsuits for hiring unsafe motor carriers. The decision in Montgomery v. Caribe Transport II, LLC reversed lower court rulings that had dismissed the case based on federal preemption. Shawn Montgomery was severely injured in 2017 when a truck hired through freight broker C.H. Robinson Worldwide struck his parked vehicle in Illinois, causing him to lose part of his leg. Montgomery sued C.H. Robinson, arguing the broker knew or should have known that the hired carrier, Caribe Transport II, had a conditional safety rating from the Federal Motor Carrier Safety Administration. What Changed The lower courts had blocked the lawsuit under the Federal Aviation Administration Authorization Act (FAAAA), which preempts most state laws affecting motor carriers and brokers. However, the Supreme Court found that common-law negligence claims fall within the FAAAA's safety exception, which protects state authority over motor vehicle safety matters. Justice Amy Coney Barrett wrote that state safety regulations and common-law duties of care are not preempted by federal law. The ruling hinged on the phrase "with respect to motor vehicles" in the FAAAA exemption. Why It Matters This decision opens brokers to potential liability for hiring decisions and could incentivize more rigorous vetting of motor carriers before assigning loads.