Docket 24-1238
Montgomery v. Caribe Transport II, LLC
DecidedMay 14, 2026
9-0unanimous decision
Source: CourtListener.
Federal law does not block injury lawsuits against trucking brokers who hire unsafe carriers
What it does
The Court held that the FAAAA's safety exception protects state-law negligent-hiring claims against transportation brokers from federal preemption (meaning federal law does not wipe out those state claims). A negligent-hiring claim — which says a company failed to use reasonable care when choosing a contractor for dangerous work — "concerns" motor vehicles and therefore falls within the safety exception. States may continue to allow injured people to sue brokers who negligently selected an unsafe trucking company.
Who benefits
People injured in truck accidents who want to sue the transportation broker that arranged the shipment, not just the trucking company or driver directly responsible for the crash.
Who is affected
Transportation brokers — companies that match shippers with trucking carriers — who now face potential state-court liability if they negligently select a carrier with a poor safety record.
Practical impact
Injured parties in truck accidents can now pursue negligent-hiring lawsuits against transportation brokers in states that recognize such claims, rather than being blocked at the courthouse door by federal preemption. Transportation brokers will need to more carefully document their carrier-selection process — particularly reviewing federal safety ratings — because a broker that knowingly hires a carrier with a poor safety record may face state tort liability. Brokers who act reasonably and select reputable carriers retain strong defenses against such suits.
Majority reasoning
The majority held that the FAAAA's safety exception preserves state authority to regulate safety "with respect to motor vehicles," and that common-law negligent-hiring claims fall squarely within that preserved authority. The Court reasoned that "with respect to" means "concerns" or "regards," following its own prior interpretation of the same phrase in the same statute, and that a claim requiring a broker to use reasonable care when selecting a trucking carrier plainly "concerns" the trucks that will transport the goods. The majority rejected the argument that this reading would swallow the FAAAA's preemption provision entirely, explaining that the safety exception saves only a subset of otherwise-preempted claims — those tied to motor vehicle safety — while leaving preempted many state laws about prices, routes, and services that have nothing to do with safety. The majority also declined to rewrite the statute to avoid a textual puzzle about why a related subsection covering intrastate broker regulation lacks a safety exception, concluding it was "better to live with the mystery than to rewrite the statute."
Constitutional question
Does the Federal Aviation Administration Authorization Act's safety exception — which preserves state authority to regulate safety "with respect to motor vehicles" — allow a person injured in a truck accident to sue the transportation broker who hired the unsafe trucking company?
Precedent changed
The ruling reverses the Seventh Circuit's decision in Ye v. GlobalTranz Enterprises, Inc., 74 F.4th 453 (2023), and resolves a circuit split by rejecting the approach also taken by the Eleventh Circuit in Aspen Am. Ins. Co. v. Landstar Ranger, 65 F.4th 1261 (2023).