The Case
Montgomery[i] involved a 2017 motor vehicle accident where an interstate motor carrier’s employee veered off Illinois Interstate 70 while driving a tractor-trailer on the job, ultimately striking a stopped driver, Shawn Montgomery, and causing Mr. Montgomery significant lasting injury and disfigurement. Montgomery’s leg ended up being amputated as a result of his injuries, and he sued the driver, the driver’s motor carrier employer (Caribe Transport II), and the freight broker (C.H. Robinson Worldwide, Inc.) that arranged the shipment with Caribe II that resulted in the accident at issue.
In part, Montgomery’s lawsuit alleged that the broker was liable for negligent hiring based on its decision to employ Caribe II as a carrier. Specifically, the lawsuit pointed to Caribe II’s “conditional” safety rating from federal regulators, citing deficiencies in driver qualifications, crash rate, and inspection, repair, and maintenance. It argued that these issues put C.H. Robinson on notice of heightened risks.
C.H. Robinson moved to dismiss under the Federal Aviation Administration Authorization Act (FAAAA), arguing that the statute preempts state-law claims against motor carriers and brokers, including those based on negligent hiring.
Both the district court and Seventh Circuit found for C.H. Robinson. Montgomery appealed to the Supreme Court of the United States.
The Court’s Ruling and Reasoning
On May 14, 2026, the Supreme Court issued its opinion, ruling unanimously in favor of Montgomery, reversing the Seventh Circuit.
The Court held that an exception to the FAAAA’s preemption provision [Section 14501(c)(2)(A)] preserves state safety regulations “with respect to motor vehicles.” The key question was whether negligent hiring suits such as those brought by Montgomery fell within that exception.
The Court concluded that they do. Interpreting “with respect to” to mean “referring to” or “concerning,” it reasoned that negligent hiring claims “concern” motor vehicle safety.
The Court also noted that trucks and trailers qualify as “motor vehicles” under the statute’s definition (a “vehicle, machine, tractor, trailer, or semitrailer propelled or drawn by mechanical power and used on a highway in transportation”). Because negligent hiring claims involve safety risks tied to those vehicles, they fit within the FAAAA’s safety exception.
The Court also addressed three counterarguments raised by C.H. Robinson.
First, it rejected the argument that applying the safety exception would undermine the FAAAA’s broader preemption clause. The Court explained that claims “concerning motor vehicle safety” are only a subset of potentially preempted claims, while state regulations (such as those relating to prices, routes, and services) remain preempted because they do not implicate safety.
Second, the Court addressed C.H. Robinson’s argument that applying the safety exception would create redundancy in light of the FAAAA’s other provisions preserving certain areas of state authority. The Court concluded that these provisions could be harmonized, noting that the other statutory grants of authority (e.g., those involving route controls or weight limits) may serve interests other than safety and are therefore not redundant.
Finally, the Court rejected the argument by C.H. Robinson and the United States that its interpretation conflicted with the statute’s broader structure, including provisions governing intrastate regulation. Although the Court acknowledged some tension between the treatment of intrastate and interstate trucking, it concluded that this inconsistency does not override the plain language of the safety exception.
Impact
As the Court noted, the federal court circuits were previously divided as to whether the application of the FAAAA’s safety exception permitted negligent hiring claims against freight brokers. With this unanimous opinion, the Court has resolved that split and clarified that such claims may proceed under state law.
As a result, brokers are well-served to exercise heightened scrutiny in retaining motor carriers and to perform a rigorous review of prospective carriers for red flags, such as those identified with Caribe II. This can help avoid being on the receiving end of this now nationally applicable negligent hiring standard if an accident occurs.
[i] Montgomery v. Caribe Transport II, LLC, et al., 608 U.S. No. 24-1238 (2026)