Montgomery v. Caribe Transport: What the U.S. Supreme Court’s Freight Broker Decision Means for Truck Accident Cases

The United States Supreme Court recently issued a significant trucking industry decision in Montgomery v. Caribe Transport II, LLC, a case addressing whether federal law bars state-law negligent hiring claims against freight brokers.

The decision involves the Federal Aviation Administration Authorization Act (FAAAA), a federal statute that preempts certain state laws affecting motor carriers and transportation brokers. For years, courts disagreed about whether federal preemption extended to claims alleging that a freight broker negligently selected an unsafe motor carrier that later caused a serious collision.

In a unanimous decision, the Supreme Court held that claims of this type fall within the FAAAA’s safety exception and are therefore not preempted by federal law.

For trucking companies, freight brokers, insurers, attorneys, and families affected by serious commercial vehicle collisions, the decision may have important implications for future litigation involving carrier selection and transportation safety.

Read the Supreme Court Opinion 

Montgomery v. Caribe Transport II, LLC, No. 24-1238 (U.S. Supreme Court, May 14, 2026) 

Official Supreme Court Opinion: 

https://www.supremecourt.gov/opinions/25pdf/24-1238_1b7d.pdf 

What Happened in Montgomery?

The case arose from a commercial vehicle collision involving petitioner Shawn Montgomery.

According to the Supreme Court’s opinion, Montgomery sustained severe and permanent injuries after his tractor-trailer was struck by a truck operated by Yosniel Varela-Mojena. At the time of the collision, Varela-Mojena was transporting a load of plastic pots for Caribe Transport II, LLC, a motor carrier. The shipment had been coordinated by C.H. Robinson Worldwide, Inc., a transportation broker.

Montgomery alleged that C.H. Robinson negligently hired Caribe Transport to perform the shipment. According to the complaint, Caribe Transport allegedly had a conditional safety rating and deficiencies involving driver qualifications, hours-of-service compliance, inspection and maintenance issues, and crash history. Montgomery contended that C.H. Robinson knew or should have known that selecting Caribe Transport created an unreasonable risk of harm to others using the roadway.

What Is a Freight Broker?

Most consumers never interact with a freight broker, but brokers play a significant role in modern transportation.

Rather than transporting freight themselves, brokers arrange transportation by connecting shippers with motor carriers. The Supreme Court described brokers as the transportation industry’s “matchmakers,” connecting sellers of goods with the carriers that move freight throughout the country.

As supply chains have become more complex, brokers have become increasingly important participants in the transportation industry. Their role often includes identifying available carriers, coordinating shipments, negotiating transportation arrangements, and facilitating movement of goods across state lines.

Understanding the FAAAA

Congress enacted the Federal Aviation Administration Authorization Act in part to reduce inconsistent state regulation affecting interstate transportation.

The statute generally prohibits states from enforcing laws related to a motor carrier’s or broker’s prices, routes, or services with respect to the transportation of property. The goal was to prevent a patchwork of state regulations from interfering with interstate commerce and the efficient movement of freight.

Over time, transportation brokers argued that negligent hiring claims were preempted because such claims affected the services brokers provide.

Several federal courts agreed.

Others disagreed.

The resulting disagreement among federal appellate courts ultimately led the Supreme Court to review the issue.

Why the Supreme Court Took the Case

The Supreme Court granted review because federal appellate courts were divided on the issue.

Before Montgomery, some courts concluded that negligent hiring claims against freight brokers were preempted by federal law, while others held that such claims fell within the FAAAA’s safety exception.

The Supreme Court specifically noted the disagreement among the federal circuits, including decisions from the Seventh, Eleventh, Sixth, and Ninth Circuits.

When federal appellate courts reach conflicting conclusions on important questions of federal law, the Supreme Court often steps in to provide a uniform nationwide answer. Montgomery provided the Court with an opportunity to resolve that disagreement.

The FAAAA Safety Exception

Although the FAAAA contains a broad preemption provision, Congress also included several exceptions.

One of those exceptions provides that the statute does not restrict “the safety regulatory authority of a State with respect to motor vehicles.”

The Supreme Court explained that the safety exception was intended to preserve the traditional authority of states to regulate matters involving public safety even while limiting state economic regulation of the transportation industry.

The dispute in Montgomery centered on whether a negligent hiring claim against a freight broker falls within that safety exception.

What Did the Supreme Court Decide?

The Supreme Court unanimously concluded that negligent hiring claims of the type asserted by Montgomery fall within the FAAAA’s safety exception.

Writing for the Court, Justice Barrett explained that the relevant question was whether the claim concerns motor vehicles.

The Court concluded that requiring a broker to exercise reasonable care when selecting a carrier necessarily concerns the trucks and vehicles that will be used to transport the shipment. Because the claim concerns motor vehicles, it falls within the safety exception and is not preempted by federal law.

The Court therefore reversed the Seventh Circuit and remanded the case for further proceedings.

Why the Court’s Reasoning Matters

One of the most significant aspects of the decision is the Court’s reasoning.

The Court did not simply announce that negligent hiring claims against brokers may proceed. Instead, it focused on the statutory language chosen by Congress.

The Court examined the phrase “with respect to motor vehicles” and concluded that a claim concerns motor vehicles when it concerns the trucks and equipment used to transport freight. Because carrier selection directly relates to the vehicles and transportation services involved in the shipment, the Court concluded that the negligent hiring claim fell within the safety exception.

That reasoning will likely influence how courts evaluate similar preemption arguments in future transportation litigation.

What the Court Did Not Decide

The decision is important, but it is equally important to understand what the Court did not decide.

The Supreme Court did not determine whether C.H. Robinson was negligent.

The Court did not determine whether Caribe Transport was unsafe.

The Court did not determine whether Montgomery ultimately will prevail on his claim.

The Court did not establish that freight brokers are automatically liable whenever a trucking collision occurs.

Instead, the Court addressed a narrower legal question: whether federal law prevents the claim from being brought at all.

The Court’s answer was that claims of this type are not barred by the FAAAA’s preemption provision because they fall within the statute’s safety exception.

Why Carrier Selection Matters in Truck Accident Cases

Modern commercial transportation often involves numerous entities working together to move freight across the country.

A single shipment may involve shippers, brokers, motor carriers, drivers, maintenance providers, insurers, and other participants.

As a result, serious trucking cases frequently involve questions regarding:

• Motor carrier safety history
• Driver qualification records
• Hours-of-service compliance
• Inspection and maintenance records
• Crash history
• Safety ratings
• Corporate policies and procedures

The allegations in Montgomery focused in part on whether information allegedly available before the shipment should have affected carrier selection decisions. While every case is different, serious trucking litigation often involves detailed investigation into the companies involved in arranging and performing transportation services.

Justice Kavanaugh’s Concurring Opinion

Justice Kavanaugh, joined by Justice Alito, wrote separately to explain why he viewed the case as a close one.

The concurrence acknowledged that the Seventh and Eleventh Circuits had raised substantial arguments supporting preemption. At the same time, the concurrence emphasized that Congress enacted the FAAAA primarily as an economic deregulation measure rather than a safety deregulation measure. The concurrence also observed that federal law contains limited safety regulation governing a broker’s selection of carriers.
Importantly, the concurrence noted that the Court’s decision should not be interpreted as creating routine liability for brokers. Traditional negligence principles, including reasonableness and causation requirements, continue to apply.

Key Takeaways From Montgomery

• The Supreme Court unanimously reversed the Seventh Circuit.
• The Court held that negligent hiring claims against freight brokers fall within the FAAAA’s safety exception.
• The decision does not establish liability against brokers.
• Traditional negligence principles remain applicable.
• Future cases will likely focus on what information was available when carriers were selected and whether reasonable care was exercised during the selection process.
• The decision resolves a significant circuit split regarding broker-related negligent hiring claims.

Questions Likely to Be Litigated Going Forward

While Montgomery resolves the preemption question presented to the Court, additional issues will likely continue to be litigated in future cases.

Examples may include:

• What information should a broker review before selecting a carrier?
• What role should safety ratings play in carrier selection?
• What evidence demonstrates reasonable care?
• How will different states apply their own negligent hiring standards?
• What facts are necessary to establish causation?

The answers to those questions will continue to develop as courts apply traditional negligence principles in future transportation cases.

Why the Decision Matters Going Forward

The transportation industry continues to evolve, and modern commercial vehicle cases often involve complex logistics networks that include shippers, brokers, motor carriers, drivers, insurers, and other entities.

The Montgomery decision addresses one important aspect of that framework: whether state-law negligent hiring claims against brokers may proceed despite the FAAAA’s preemption provision.

As courts continue applying the decision, additional questions may arise regarding carrier selection practices, broker responsibilities, available safety information, and how traditional negligence standards apply in specific cases.

For now, the Supreme Court has clarified that negligent hiring claims involving carrier selection are not categorically barred by federal preemption simply because a transportation broker is involved.

Goldstein Hayes Perspective

Commercial trucking cases often involve far more than the actions of a single driver. Modern freight transportation frequently includes multiple companies responsible for different aspects of the shipment process, including shippers, brokers, motor carriers, logistics providers, and insurers.

As the Supreme Court recognized in Montgomery, carrier selection can be an important component of transportation safety. The Court’s decision does not determine liability, nor does it mean that a broker is responsible every time a collision occurs. Rather, the decision confirms that courts may evaluate negligent hiring allegations under applicable state law rather than ending the inquiry based solely on federal preemption.

From a litigation perspective, cases involving catastrophic injuries and wrongful death often require a detailed examination of the events and decisions that occurred before a truck ever entered the roadway. That may include reviewing safety ratings, compliance histories, driver qualification issues, inspection and maintenance records, crash histories, corporate policies, and other information relevant to the transportation arrangement.

Montgomery will likely remain an important decision in trucking litigation because it addresses a threshold issue that frequently determines whether those facts can be fully examined in court. As transportation networks become increasingly complex, questions involving carrier selection, safety practices, and corporate responsibility will continue to play a significant role in serious commercial vehicle cases.

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