Montgomery v. Caribe Transport II, LLC
Whether the Federal Aviation Administration Authorization Act of 1994 preempts state-law negligence claims against freight brokers who arrange transportation of property by motor carriers.
Background & Facts
Shawn Montgomery was seriously injured when a truck driven by a driver employed by Caribe Transport II, LLC collided with his vehicle. The truck had been dispatched by C.H. Robinson, a major freight broker that arranges shipments between shippers and motor carriers for a fee. Montgomery sued both the trucking company and C.H. Robinson, alleging that C.H. Robinson was negligent in selecting an unsafe carrier to haul the load. His claim against C.H. Robinson rested on a traditional state common-law theory: that a party who hires a contractor to do dangerous work has a duty to exercise reasonable care in choosing a competent contractor.
The central legal dispute is whether the Federal Aviation Administration Authorization Act of 1994 (FAAAA) blocks Montgomery's negligence claim. That federal law prohibits states from enforcing any law 'related to a price, route, or service of any... broker' in order to prevent a patchwork of state regulations from interfering with the deregulated trucking market. C.H. Robinson argued that allowing a state tort claim based on its brokerage services is exactly the kind of state interference Congress intended to prevent. The federal district court agreed and dismissed the claim, and the Seventh Circuit Court of Appeals affirmed that ruling in January 2025, finding Montgomery's negligence claim preempted by federal law. Montgomery then petitioned the Supreme Court, which agreed to hear the case.
Why This Case Matters
This case will resolve a deep split among the federal circuit courts on a question that directly affects public safety on American roads. Some circuits have held that state negligence claims against freight brokers are preempted by the FAAAA, while others have allowed such suits to proceed. The Supreme Court's ruling will set a uniform national rule on whether injured victims can hold freight brokers accountable in court for negligently selecting dangerous trucking companies.
The stakes are enormous for both safety advocates and the logistics industry. Freight brokers like C.H. Robinson arrange millions of shipments annually and have significant leverage to screen out unsafe carriers. If preemption applies, injured plaintiffs lose a meaningful avenue of legal redress and brokers face no state-law tort liability for their carrier-selection decisions, which safety advocates warn could reduce incentives to weed out dangerous operators. On the other hand, the trucking and logistics industry warns that exposing brokers to state tort liability in all fifty states would undermine the deregulated national market Congress created and dramatically increase costs for brokers, shippers, and ultimately consumers.
The Arguments
State common-law negligence claims against freight brokers for negligent selection of a motor carrier are not preempted by the FAAAA because they do not sufficiently 'relate to' a broker's prices, routes, or services in the manner Congress intended. A generally applicable duty of care in hiring contractors is not a state regulation targeting the trucking industry, and allowing such claims serves the background safety principles that Congress did not intend to displace.
- The FAAAA preemption clause targets economic regulation of rates and services, not traditional tort law governing reasonable care in selecting dangerous contractors.
- The Supreme Court has recognized that general negligence principles are not the kind of state 'laws' Congress meant to preempt when it deregulated transportation markets.
- Congress expressly preserved state tort law in analogous deregulation statutes, and the Court should not read a broad tort preemption into silence.
- Holding brokers immune from negligence suits removes a critical incentive to screen out unsafe carriers, endangering the public with no offsetting federal remedy.
The FAAAA's broad preemption clause—barring state laws 'related to' a broker's prices, routes, or services—encompasses state negligence claims that directly target how a freight broker selects and arranges motor carriers, because such claims impose standards of conduct on core brokerage services. Allowing these suits would recreate through litigation the same patchwork of state regulation Congress eliminated when it deregulated the trucking industry.
- The FAAAA's text sweeps broadly, preempting any state law having a connection with or reference to broker services, which includes tort duties governing carrier selection.
- A negligence verdict against a broker for choosing a carrier functions as a judicially imposed standard for brokerage services—exactly the kind of state regulation preempted by the FAAAA.
- Congress modeled the FAAAA on the Airline Deregulation Act, and the Court has applied broad preemption to that statute; the same logic applies here.
- The federal regulatory scheme already addresses carrier safety through DOT oversight, leaving no gap that state tort law needs to fill.
Precedent Cases Cited
Morales v. Trans World Airlines, Inc.
504 U.S. 374
Established that the Airline Deregulation Act's 'related to' preemption clause has broad sweep, preempting state laws having a connection with airline rates, routes, or services; respondents argue the identical FAAAA language should be read just as broadly.
American Airlines, Inc. v. Wolens
513 U.S. 219
Carved out a limited exception allowing suits based on a party's own contractual undertakings even under broad airline deregulation preemption, which petitioner argues supports permitting tort claims not targeting regulatory standards.
Rowe v. New Hampshire Motor Transport Association
552 U.S. 364
Applied broad FAAAA preemption to strike down state trucking regulations, confirming that the statute's language tracks the ADA's and is intended to have equivalent broad scope.
Dan's City Used Cars, Inc. v. Pelkey
569 U.S. 251
Clarified the limits of FAAAA preemption, holding that a state tort claim unrelated to the transportation of property was not preempted, supporting petitioner's argument that not every state-law claim touching a broker is preempted.
Northwest, Inc. v. Ginsberg
572 U.S. 273
Further elaborated on the breadth of ADA preemption in the airline context and the distinction between generally applicable background law and targeted regulation, relevant to whether common-law negligence is preempted.
Wolff v. Truck Transportation
One of the circuit court decisions creating the circuit split that prompted Supreme Court review, illustrating the conflict among lower courts on whether FAAAA preempts broker negligence claims.
Legal Terminology
Analysis & Opinions
The Supreme Court will hear oral arguments in Montgomery v. Caribe Transport II on March 4, addressing whether a federal law originally designed to address state trucking regulations preempts state-law claims holding freight brokers liable for negligent hiring. The case concerns the scope of federal preemption in the trucking industry.