Montgomery v. Caribe Transport II, LLC

Questions presented

SCOTUS records, cert granted 3 Oct 2025

The common law permits a cause of action for negligent selection. For example, a person injured in a truck crash has a cause of action against someone that negligently selected the truck driver to transport property. A federal statute expressly preempts state laws "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." 49 U.S.C. § 14501(c)(1). The statute has a safety exception, providing that the statute "shall not restrict the safety regulatory authority of a State with respect to motor vehicles." Id. § 14501(c)(2)(A). The question presented is: Does§ 14501(c) preempt a state common-law claim against a broker for negligently selecting a motor carrier or driver?

Opinion summary

Etalia.ai summary of the majority opinion

The case asked whether the Federal Aviation Administration Authorization Act bars a state-law negligent-hiring claim against a transportation broker. Shawn Montgomery was badly injured when a truck carrying goods for Caribe Transport struck his tractor trailer, and he sued C.H. Robinson Worldwide, which had arranged the shipment, alleging it negligently hired Caribe Transport and the driver. The Court, in an opinion by Justice Barrett, held that the claim is not preempted because the Act’s safety exception preserves a state’s authority to regulate safety “with respect to motor vehicles.” The Court reasoned that negligent-hiring claims are part of a state’s safety authority and that requiring a broker to use reasonable care in selecting a carrier concerns motor vehicles. The Court rejected arguments that this reading created surplusage or conflicted with other parts of the statute. The judgment was reversed and remanded.