
U.S. Supreme Court Rules that Freight Brokers Can Be Liable for Personal Injuries Resulting from Trucking Accidents
On May 14, 2026, the U.S. Supreme Court decided in Montgomery v. Caribe Transport II that freight brokers can be sued for negligently hiring unsafe trucking companies. Here’s what happened and what the ruling means:
Background
In 2017, Shawn Montgomery was severely injured when his stopped vehicle was rear-ended by a semi-truck, resulting in the amputation of his leg and permanent disfigurement. Montgomery sued three parties:
- The driver of the semi-truck
- The driver’s employer, Caribe Transport II, which is a motor carrier (i.e. trucking company) that owns and operates semi-trucks
- The freight broker, C.H. Robinson. A freight broker is a “middleman” company that sellers of goods use to arrange shipments of their goods by motor carriers. In this case, C.H. Robinson contracted with Caribe Transport II to ship a load of plastic pots. C.H. Robinson is one of the largest freight brokers in the U.S.
The Lawsuit
For Montgomery’s claim against C.H. Robinson, he argued that the broker should be held liable because it knew, or should have known, that Caribe Transport II was unsafe to hire. This legal theory is called negligent hiring—meaning when you hire someone (or in this case, contract with a company) to do work that could harm others, you have a duty to exercise reasonable care in choosing that contractor.
Specifically, Montgomery alleged that federal regulators had given Caribe Transport II a “conditional” safety rating, finding it deficient in areas like driver qualification, hours of service, and crash rates. Because semi-truck accidents can result in catastrophic injuries, trucking companies are subject to strict safety regulations addressing the common causes of those crashes. The federal safety ratings make safety information publicly available so that shippers, brokers, and consumers can make informed decisions about which carriers to hire.
The Legal Dispute and Federal Law
The central dispute centered on the Federal Aviation Administration Authorization Act of 1994 (FAAAA), which was designed to deregulate the trucking industry and create uniform national rules rather than each state imposing its own restrictions. Section 14501(c)(1) of this law preempts—meaning overrides or blocks—state laws “related to a price, route, or service” of motor carriers or brokers. C.H. Robinson argued that a negligent-hiring lawsuit qualifies as a state law “related to service,” so it should be blocked.
However, the FAAAA has an exception. Section 14501(c)(2)(A) states that the preemption doesn’t apply to “the safety regulatory authority of a State with respect to motor vehicles.” This carves out space for states to enforce their own safety rules. Montgomery argued that this exception applied, but the district court and the 7th Circuit Court of Appeals sided with C.H. Robinson.
The Court’s Holding
The Supreme Court, in a unanimous decision, sided with Montgomery. Justice Amy Coney Barrett, writing for the 9-0 court, explained that a negligent-hiring lawsuit “concerns” or “regards” motor vehicle safety and thus falls squarely within the exception.
The Court’s Rejection of C.H. Robinson’s Arguments
C.H. Robinson made three arguments to try to convince the Court to rule in its favor:
- The “Swallow Whole” Argument: Joined by the United States as amicus curiae, C.H. Robinson argued that if the safety exception applies here, won’t states just claim that safety applies to everything that Congress meant to preempt, making the preemption meaningless? The Court disagreed, noting that the safety exception only covers laws specifically “concerning motor vehicle safety,” not rules about what prices carriers can charge or which highways they use.
- The “Unnecessary Overlap” Argument: C.H. Robinson argued that the statute already preserved some state authority, so a specific safety carveout would be redundant. The Court determined that some overlap exists regardless of how you read the phrase, and the overlapping sections can serve different purposes.
- The “Anomaly” Argument: The FAAAA treats intrastate shipping (within one state) differently from interstate shipping (across state lines)—it preempts state oversight of intrastate broker regulation but has no safety exception for that section. C.H. Robinson asked why Congress would shield brokers for in-state trips but not interstate ones. The Court acknowledged the structural oddity but said Congress’s actual text controls the outcome. Justice Barrett noted that it’s “better to live with the mystery than to rewrite the statute.”
A Cautionary Note from One Justice
Justice Brett Kavanaugh, joined by Justice Samuel Alito, agreed with the outcome but noted that the case was “closer than the Court’s opinion perhaps might suggest.” He stressed that the ruling should not be understood as opening brokers to routine liability—those that act reasonably and select reputable carriers “should be able to successfully defend against state tort suits.”
What This Means for Personal Injury Plaintiffs
The Montgomery ruling allows injured people to sue freight brokers in state court under state law if they can show that the broker negligently hired an unsafe carrier. It doesn’t guarantee they’ll win, but they can’t be blocked before trial simply because federal deregulation law preempts state regulation of trucking services generally.
Having an attorney who understands the landscape of federal laws that apply to trucking carriers can make a substantial difference in the outcome of your claim. The attorneys at Sieben & Cotter have extensive expertise with semi-truck injury cases. If you are interested in a free, comprehensive case review, call Sieben & Cotter at 651-455-1555 to arrange your consultation, or send a request for more information.