Supreme Court rules that freight brokers can be held accountable for negligence in commercial vehicle crashes

The U.S. Supreme Court issued a landmark ruling on whether freight brokers are protected from lawsuits under state law in injury or fatality crashes involving the commercial vehicles that they hire.

On Thursday, May 14, the Supreme Court handed down a unanimous opinion in favor of Shawn Montgomery in the case MONTGOMERY v. CARIBE TRANSPORT II, LLC.

Montgomery suffered severe injuries in a crash involving truck driver Yosniel Varela-Mojena, who was hauling a load of plastic pots through Illinois for motor carrier Caribe Transport II, LLC. when the crash occurred in 2017. Montgomery’s vehicle was parked on the shoulder when it was struck by Varela-Mojena’s truck. Montgomery lost part of his leg in the crash.

The shipment was coordinated by freight broker C.H. Robinson Worldwide, Inc.

Following the crash, Montgomery filed a lawsuit in Federal District Court arguing that C.H. Robinson was negligent in hiring Caribe Transport and Varela-Mojena because “C.H. Robinson knew (or should have known) from Caribe Transport’s safety rating that hiring it to transport goods was reasonably likely to result in crashes that would injure others.”

Montgomery’s suit argued that Caribe Transport had a “conditional” safety rating from the Federal Motor Carrier Safety Administration when C.H. Robinson hired it.

The District Court ruled against Montgomery based on the Federal Aviation Administration Authorization Act (FAAAA), which says that states “may not enact or enforce a law, regulation, or other provision having the force and effect of law related to a price, route, or service of any motor carrier … or any motor private carrier, broker, or freight forwarder with respect to the transportation of property.”

The District Court also found that the suit did not fall within FAAAA’s safety exception, which provides that the FAAAA’s preemption provision “shall not restrict the safety regulatory authority of a State with respect to motor vehicles.”

The Seventh Circuit affirmed the District Court’s ruling in January 2025, and the case was eventually kicked up to the U.S. Supreme Court.

C.H. Robinson maintained that because trucking is a federally-regulated industry, it should be protected from being sued under state law, but the high court sided against the broker.

“Montgomery argues that even if the FAAAA otherwise preempts his negligent-hiring claim against C.H. Robinson, the safety exception saves it. We agree,” Justice Amy Coney Barrett wrote in the opinion overturning the Seventh Circuit’s ruling. “Recall the relevant text: The preemption provision “shall not restrict the safety regulatory authority of a State with respect to motor vehicles.” All agree that common-law duties and standards of care form part of a State’s authority to regulate safety.”

The ruling ultimately hinged on the phrase “with respect to motor vehicles” in the FAAA safety exemption.

“The preemption question thus boils down to whether negligent-hiring claims of the type Montgomery presses are claims “with respect to motor vehicles.” We conclude that they are,” Barrett wrote.

“Applying that interpretation here is straightforward. Montgomery alleges that C.H. Robinson failed to exercise reasonable care when it hired Caribe Transport, which had a subpar safety rating from federal regulators, to transport goods via truck. Based on that safety rating, Montgomery claims that C.H. Robinson knew (or should have known) that choosing Caribe Transport to move goods was reasonably likely to cause an accident. Requiring C.H. Robinson to exercise ordinary care in selecting a carrier therefore “concerns” motor vehicles—most obviously, the trucks that will transport the goods. So Montgomery’s negligent-hiring claim falls within the FAAAA’s safety exception, which saves it from preemption,” Barrett concluded.

C.H. Robinson responded to the ruling.

“Our hearts continue to go out to the victims of truck accidents,” said Dorothy Capers, Chief Legal Officer at C.H. Robinson. “Safety is foundational to who we are—our employees and their families travel these same roads, and our business depends on safe freight delivery. While we are disappointed in the Court’s decision, we will continue to operate responsibly, support stronger federal enforcement, and work constructively with regulators, carriers, and customers to strengthen the national safety system and support safe, reliable transportation across the country. As Justices Kavanaugh and Alito stated in the concurrence, ‘Importantly, the Court’s decision today should not be read to mean that brokers will routinely be subject to state tort liability in the wake of truck accidents.’”

The Supreme Court’s ruling leaves could have a massive impact on the freight brokerage industry, opening the door for a wave of negligence lawsuits.