The relationship between freight brokers and motor carriers is a central part of interstate trucking. Brokers arrange transportation, while carriers operate the trucks and employ or contract with drivers.
When a serious crash occurs, questions can arise about whether the broker used reasonable care when selecting the carrier.
The Supreme Court addressed an important part of that issue in Montgomery v. Caribe Transport II, LLC.
On May 14, 2026, the Court unanimously held that the Federal Aviation Administration Authorization Act does not preempt the type of state-law negligent-hiring claim brought against the freight broker in this case.
The ruling is important, but it does not make every freight broker automatically liable for a motor carrier’s crash.
What Happened in Montgomery v. Caribe Transport?
On December 7, 2017, truck driver Shawn Montgomery was seriously injured when another tractor-trailer struck his stopped truck on an Illinois highway shoulder.
The other vehicle was driven by Yosniel Varela-Mojena, who was working for Caribe Transport II, LLC.
Freight broker C.H. Robinson Worldwide had arranged the shipment.
Montgomery alleged that C.H. Robinson failed to use reasonable care when selecting Caribe Transport, which he claimed had a problematic safety record.
The litigation raised questions about the responsibilities of brokers that arrange transportation with independent motor carriers.
What Did the Lower Courts Decide?
The federal district court dismissed the negligent-hiring claim against C.H. Robinson on federal preemption grounds.
The Seventh Circuit affirmed that decision.
The lower courts concluded that the Federal Aviation Administration Authorization Act, commonly called the FAAAA, barred the relevant state-law claim.
The appellate court also rejected a separate vicarious-liability theory based on the facts of the independent-contractor relationship.
Those were distinct legal issues.
What Is the FAAAA?
The FAAAA generally limits state regulation related to the prices, routes, and services of motor carriers, brokers, and certain other transportation businesses.
Congress adopted that framework to prevent inconsistent state regulation from interfering with interstate transportation.
However, the statute includes an important exception.
Under 49 U.S.C. § 14501(c)(2)(A), states retain safety regulatory authority with respect to motor vehicles.
The central question in Montgomery was whether that exception includes a negligent-hiring claim against a freight broker.
What Did the Supreme Court Decide?
The Supreme Court unanimously ruled on May 14, 2026, that the relevant negligent-hiring claim falls within the FAAAA’s motor vehicle safety exception.
Justice Amy Coney Barrett authored the Court’s opinion.
The Court explained that requiring reasonable care in selecting a trucking company concerns the motor vehicles used to transport freight.
The Supreme Court reversed the Seventh Circuit’s judgment and returned the case for further proceedings.
Did the Court Find C.H. Robinson Negligent?
No.
The ruling resolved the federal preemption question, not whether C.H. Robinson actually breached a duty of care or caused Montgomery’s injuries.
Those questions depend on the evidence and applicable law in further proceedings.
The decision allows the relevant type of claim to be considered. It does not guarantee that a plaintiff will win.
Are Brokers Responsible for Every Carrier Crash?
No.
The decision does not establish automatic broker liability.
A plaintiff still must satisfy the elements of the applicable state-law claim, which may include duty, breach, causation, and damages.
The precise requirements depend on the jurisdiction and facts.
The ruling also does not eliminate the motor carrier’s own safety responsibilities.
What Does This Mean for Freight Brokers?
Brokers should review how they select and monitor motor carriers.
A documented process can help demonstrate the information considered before a carrier was assigned a shipment.
Practical checks may include operating authority, company identity, insurance information, and available safety records.
A process should be applied consistently and updated when new information becomes available.
How Can Brokers Check a Carrier’s Safety Information?
FMCSA’s SAFER Company Snapshot provides public information about a motor carrier.
Available data can include identification information, fleet size, safety rating when one exists, roadside inspection summaries, and crash information.
A broker should understand that these fields have different meanings.
An active USDOT number alone is not proof that a carrier has an excellent safety record.
Should Brokers Verify Operating Authority?
Yes, when the transportation requires it.
A broker should confirm that the motor carrier has the authority appropriate for the service being arranged.
Authority status and insurance information should be reviewed through current FMCSA resources.
Registration data can change, so an old screenshot should not be treated as permanent verification.
What Responsibilities Remain With Motor Carriers?
Motor carriers remain responsible for their applicable federal safety obligations.
These may include driver qualification, hours of service, vehicle maintenance, inspections, drug and alcohol testing, and insurance requirements.
A broker’s carrier-selection process does not replace the carrier’s responsibility to operate safely.
Likewise, a motor carrier should not assume that a broker’s approval establishes complete compliance.
Does an Independent-Contractor Agreement Prevent Liability?
Not necessarily.
The lower courts separately considered whether C.H. Robinson exercised enough control over Caribe Transport to support vicarious liability.
The Supreme Court’s decision did not establish that independent-contractor agreements automatically prevent negligent-selection claims.
Contract language matters, but the applicable legal theory and actual conduct also matter.
Could the Decision Change Broker Practices?
It may encourage brokers to review their carrier-selection procedures and recordkeeping.
However, the decision does not establish a mandatory federal screening checklist.
It also does not prove that insurance premiums or freight prices will increase by a particular amount.
Companies should evaluate operational changes based on their actual risks and legal obligations.
Frequently Asked Questions
When did the Supreme Court decide Montgomery v. Caribe Transport?
May 14, 2026.
Was the decision unanimous?
Yes.
Did the Supreme Court rule that C.H. Robinson caused the crash?
No. The Court decided the federal preemption issue.
Can a broker be sued for negligently selecting an unsafe carrier?
The type of state-law negligent-hiring claim at issue is not barred by the FAAAA’s general preemption provision.
Does a valid USDOT number prove a carrier is safe?
No. Registration and safety performance are separate matters.
Does the ruling change federal motor carrier safety regulations?
The ruling addresses state-law liability and federal preemption. It does not replace existing FMCSA safety regulations.
Strengthen Carrier Compliance and Safety Readiness
The Montgomery decision highlights the importance of accurate carrier information, reasonable transportation decisions, and ongoing motor carrier safety compliance.
MCS-150 Biennial Update Filing Services – Fmcsa.com provides private education and assistance with federal motor carrier requirements, including USDOT registration, operating authority, and safety compliance topics.
Visit MCS-150 Biennial Update Filing Services – Fmcsa.com or call (800) 454-2522 for assistance understanding federal motor carrier compliance responsibilities.
MCS-150 Biennial Update Filing Services – Fmcsa.com is a private compliance resource and is not the Federal Motor Carrier Safety Administration or an official government website. This article provides general information, not legal advice. Consult qualified legal counsel for questions about liability or litigation.
