Supreme Court Expands Freight Broker Liability in Landmark Decision (Montgomery v. Caribe Transport II, LLC)

Supreme Court Expands Freight Broker Liability in Landmark Decision (Montgomery v. Caribe Transport II, LLC)

Introduction

Supreme Court Decision Overview (May 14, 2026)

On May 14, 2026, the United States Supreme Court issued a unanimous 9–0 decision in Montgomery v. Caribe Transport II, LLC, a significant case addressing the scope of freight broker liability under federal transportation law. The Court held that state-law negligent hiring claims against freight brokers are not preempted by the Federal Aviation Administration Authorization Act (FAAAA), thereby allowing such claims to proceed under state tort law when safety concerns are involved.

The decision clarifies the relationship between federal deregulation of the transportation industry and traditional state authority over motor vehicle safety. It also resolves a longstanding circuit split regarding whether freight brokers could be shielded from negligence claims arising from their selection of motor carriers.

The opinion of the Court was authored by Justice Amy Coney Barrett, with a concurring opinion by Justice Brett Kavanaugh, joined by Justice Samuel Alito, emphasizing that while the question was close, Congress did not intend to fully immunize brokers from safety-based negligence claims.

Factual Background of the Case

The case arose from a serious highway collision in Illinois involving plaintiff Shawn Montgomery, a commercial truck driver who suffered catastrophic injuries, including the loss of his leg, after his stationary tractor-trailer was struck by a vehicle operated by a motor carrier arranged through brokerage services.

The carrier involved in the crash, Caribe Transport II, LLC, had been selected through a freight brokerage arrangement linked to C.H. Robinson Worldwide, one of the largest logistics brokers in the United States. The plaintiff alleged that the broker failed to properly vet the carrier’s safety record and hired a company with a known history of violations and prior safety concerns.

Montgomery argued that a reasonable and proper background check would have revealed the carrier’s unsafe operational history, and that this failure directly contributed to the collision and resulting injuries. The claim was therefore brought under state-law negligence principles, specifically negligent hiring and selection of motor carriers.

Legal Question Before the Supreme Court

The central legal question before the Court was whether the FAAAA preempts state-law negligence claims against freight brokers based on their selection of motor carriers.

The FAAAA generally prohibits states from enacting laws “related to a price, route, or service” of a motor carrier or broker, as part of a federal effort to deregulate the transportation industry. However, the statute also contains a critical exception preserving the “safety regulatory authority of a State with respect to motor vehicles.”

The Court was tasked with determining whether negligent hiring claims fall within this safety exception or whether they are indirectly barred as regulations affecting broker services.

Supreme Court’s Holding and Legal Reasoning

The Supreme Court held that negligent hiring claims against freight brokers fall within the FAAAA’s safety exception and are therefore not preempted by federal law. Justice Barrett’s opinion emphasized that such claims directly implicate motor vehicle safety because they arise from decisions about which carriers and drivers are permitted to operate on public highways.

The Court rejected arguments advanced by C.H. Robinson and industry stakeholders that allowing such claims would create a fragmented regulatory environment or undermine federal uniformity in transportation policy. Instead, the Court found that Congress explicitly preserved state authority over safety-related tort claims, and that negligent hiring actions fall squarely within that preserved domain.

In his concurrence, Justice Kavanaugh, joined by Justice Alito, noted that the statutory language presented a “close question,” but agreed that the most faithful reading of the statute supports allowing state negligence claims where public safety is directly implicated. The concurrence further acknowledged that brokers do not receive blanket immunity from tort liability when their conduct may contribute to unsafe highway conditions.

Impact on Freight Brokers and Transportation Industry

The ruling carries significant implications for freight brokers, who act as intermediaries between shippers and motor carriers. Brokers now face increased exposure to litigation arising from allegations that they failed to properly vet carriers with poor safety histories or regulatory violations.

By rejecting the broad preemption defense that had previously been used in multiple federal circuits, the Court has opened the door for plaintiffs to pursue discovery and trial on whether brokers exercised reasonable care in selecting carriers. This shift is expected to increase litigation involving broker negligence claims in trucking accident cases nationwide.

Industry groups have expressed concern that the decision may increase insurance costs and operational risk for logistics companies. However, safety advocates argue that the ruling strengthens accountability within the supply chain and encourages more rigorous carrier screening practices.

Lower Court Proceedings and Circuit Split Resolution

Before reaching the Supreme Court, the case reflected a well-established circuit split. The Seventh Circuit had previously ruled in favor of preemption, effectively shielding freight brokers from negligent hiring claims under the FAAAA. Other federal appellate courts had reached different conclusions, allowing such claims to proceed under state law.

The Supreme Court’s decision resolves this inconsistency by establishing a uniform national rule: state-law negligence claims against freight brokers are not preempted when they relate to motor vehicle safety. The case was remanded for further proceedings consistent with the Court’s opinion, allowing the underlying negligence claim to proceed in lower court.

Broader Legal and Policy Implications

Legal scholars have characterized the decision as an important clarification of the balance between federal deregulation and state tort law. The ruling reinforces the principle that federal transportation statutes do not completely displace state authority over public safety matters.

The decision is expected to influence future litigation involving trucking accidents, particularly cases involving broker selection of unsafe or non-compliant carriers. It may also prompt freight brokers to adopt more comprehensive due diligence practices, including enhanced safety evaluations, compliance monitoring, and carrier qualification standards.

In addition, the ruling is likely to affect contractual relationships within the logistics industry, as brokers, insurers, and shippers reassess risk allocation and liability exposure in transportation agreements.

Post-Decision Industry and Legal Response

Following the ruling, transportation industry stakeholders reacted with mixed responses. Some logistics and trade groups warned that the decision could lead to increased compliance costs and varying state-level liability standards, potentially complicating interstate operations.

On the other hand, plaintiff attorneys and transportation safety advocates have described the ruling as a meaningful step toward improving highway safety accountability. They argue that brokers play a central role in selecting carriers and therefore should bear responsibility when negligent selection contributes to preventable accidents.

Courts across multiple jurisdictions have already begun referencing the decision in ongoing broker liability cases, signaling its immediate influence on pending litigation.

Expanded Legal Framework After Montgomery Decision

Following the Montgomery ruling, freight brokers are now required to exercise reasonable care in the selection of motor carriers, with courts likely to assess broker conduct based on carrier safety records, regulatory compliance history, and prior accident involvement.

This development introduces a more structured framework for evaluating broker negligence claims and is expected to significantly shape litigation strategies in trucking-related personal injury cases. Attorneys on both sides anticipate increased discovery disputes focused on broker vetting procedures, internal safety protocols, and documentation of carrier selection decisions.