Montgomery v. Caribe Transport II Reaction

The case asks whether the Federal Aviation Administration Authorization Act of 1994 (FAAAA) preempts state negligence claims against freight brokers for carelessly selecting unsafe motor carriers or drivers. The crash happened December 7, 2017, on Interstate 70 in Illinois. Missouri truck driver Shawn Montgomery had pulled his 2015 Mack truck onto the shoulder for mechanical repairs. While standing outside, he was struck from behind by a speeding 1995 Freightliner tractor-trailer driven by Yosniel Varela-Mojena. Montgomery lost his leg and suffered permanent disfigurement.Varela-Mojena worked for Indiana-based Caribe Transport II, which owned the tractor. The trailer was leased from a related Florida company. Freight broker C.H. Robinson arranged the shipment of plastic pots from Ohio to Arkansas and Texas under a contract with Caribe II. Montgomery sued under state law, claiming negligence against the driver, the carriers, and Robinson for negligent hiring. Robinson argued the FAAAA’s Section 14501(c)(1) preempts the claims because they relate to a broker’s “price, route, or service” in transporting property. The district court said the claims related to broker services but fit the safety exception in Section 14501(c)(2)(A), which preserves state “safety regulatory authority… with respect to motor vehicles.” The 7th Circuit held that negligent-hiring claims against brokers are preempted. Montgomery argues to the Supreme Court that his claims are not preempted. He says the FAAAA targets economic regulations, not safety-based torts. The safety exception protects states’ traditional authority over motor vehicles, and requiring brokers to use reasonable care when hiring carriers falls within that power. He warns broad preemption could leave victims without remedies and encourage brokers to choose risky carriers for profit.Robinson and the other respondents reply that state tort claims like negligent hiring are expressly preempted by the statute’s plain text. The safety exception applies only to rules with a “direct connection” to motor vehicles. Brokers do not own or operate vehicles, so states lack authority to impose personal injury liability on them. Policy concerns cannot override the law’s wording. The U.S. government filed a brief supporting the respondents, arguing the text requires a direct link to vehicles, and a broker’s duty to select carriers carefully does not qualify. The government reversed its prior position after new review and court developments.The outcome is hard to predict, especially with the government’s shift. Oral argument will likely feature questions about what counts as a “direct connection” to motor vehicles.This program is brought to you by DAT Freight & Analytics. Since 1978, DAT has helped truckers & brokers discover more available loads. Whether you're heading home or looking for your next adventure, DAT is building the most trusted marketplace in freight. New users of DAT can save 10% off for the first 12 months by following the link below. Built on the latest technology, DAT One gives you control over every aspect of moving freight, so that you can run your business with speed & efficiency.This program is also brought to you by our newest sponsor, GenLogs. GenLogs is setting a new standard of care for freight intelligence. Book your demo for GenLogs today at www.genlogs.io today!