On May 14, 2026, the U.S. Supreme Court issued a unanimous decision in Montgomery v. Caribe Transport II, LLC. The Court held that federal law does not block state-law negligent-hiring claims against freight brokers. As a result, injured people can now sue brokers that arrange shipments with unsafe motor carriers. The ruling resolves a long-running circuit split. It also carries real consequences for anyone hurt in a crash involving a commercial truck. In this post, we walk through the case, the Court’s reasoning, and what the decision could mean for victims of truck accidents in Washington, D.C. and Maryland.
The full slip opinion is posted on the Court’s website at supremecourt.gov. In addition, background reporting is available from SCOTUSblog and Oyez. The discussion below is for general information only. It is not legal advice.
How the Case Arose
Shawn Montgomery was driving a tractor-trailer through Illinois. Suddenly, a truck operated by Yosniel Varela-Mojena veered off course and struck his vehicle, which was stopped on the shoulder. According to the opinion, Mr. Montgomery’s leg had to be amputated. He also sustained other severe and permanent injuries. As a result, his case became the vehicle for resolving an important federal question about preemption in trucking.
Varela-Mojena was driving for Caribe Transport II, LLC, a motor carrier. However, the shipment had been coordinated by C.H. Robinson Worldwide, Inc., one of the largest freight brokers in the country. Mr. Montgomery sued the driver, the carrier, and the broker. In particular, he alleged that C.H. Robinson negligently hired Caribe Transport. He pointed out that the carrier already held a “conditional” safety rating from the Federal Motor Carrier Safety Administration (FMCSA). The rating reflected documented issues with driver qualifications, hours of service, vehicle inspection and maintenance, and the carrier’s recordable crash rate.
The District Court dismissed the negligent-hiring claim on preemption grounds. Later, the Seventh Circuit affirmed. The Supreme Court then granted certiorari to resolve a split among the federal courts of appeals. In short, that split had produced inconsistent outcomes from one region to another. A uniform national rule was clearly needed.
What Freight Brokers Do
Freight brokers serve as intermediaries between shippers and trucking companies. They do not own the trucks. They also do not employ the drivers. Instead, they connect a customer’s load with a carrier that will haul it. According to figures cited in the opinion, roughly 28,000 brokers arrange about one-third of all freight shipped in the United States. Together, they work with more than 780,000 carriers. As a result, broker accountability for carrier selection has become an increasingly important issue. The U.S. Department of Transportation continues to track growing freight volumes on the nation’s highways. The economic stakes are large, and so are the safety stakes.
The Preemption Problem
The legal question in Montgomery turned on the Federal Aviation Administration Authorization Act of 1994. The statute is commonly called the FAAAA. Codified at 49 U.S.C. § 14501, it expressly preempts state laws “related to a price, route, or service” of any motor carrier or broker. Congress enacted this broad clause to deregulate the trucking industry economically. In addition, lawmakers wanted to remove inconsistent state rules that interfered with interstate commerce.
However, the FAAAA also includes what the Court called a “safety exception.” That exception preserves the “safety regulatory authority of a State with respect to motor vehicles.” The question for the Court was whether that exception covers state negligent-hiring claims against brokers. The Seventh and Eleventh Circuits had ruled such claims were preempted. In contrast, the Sixth and Ninth Circuits had held they were not. As a result, the same facts could produce very different outcomes depending on geography. The Court took the case to provide one clear national answer.
The Court’s Holding
Writing for a unanimous Court, Justice Amy Coney Barrett held that the FAAAA’s safety exception saves Mr. Montgomery’s claim. The opinion proceeds in three clear steps.
First, every party agreed on an important point. State common-law duties and standards of care form part of a state’s authority to regulate safety. A negligent-hiring claim imposes a duty of reasonable care. That duty applies when one company employs another contractor for work involving a risk of physical harm. In short, this duty is a familiar feature of state tort law. It falls within the traditional police power that states use to protect the public.
Second, the Court interpreted the phrase “with respect to” using its ordinary meaning. Standard dictionary definitions treat the phrase as “referring to,” “concerning,” or “regarding.” The Court also relied on its earlier decision in Dan’s City Used Cars, Inc. v. Pelkey. In that case, the Court construed the same phrase in the same statute to mean “concerns.”
Third, the FAAAA itself defines “motor vehicle.” The term includes trucks, trailers, and similar equipment used in transportation. Putting the pieces together, the Court reasoned that a claim is “with respect to motor vehicles” when it “concerns” those vehicles. Requiring a broker to use ordinary care when picking a carrier clearly concerns the trucks that will haul the load. Therefore, the negligent-hiring claim falls within the safety exception and is not preempted.
Rejecting the Broker’s Counterarguments
C.H. Robinson, joined in part by the United States, raised several counterarguments. The Court addressed each one in turn.
First, the broker argued that this reading would swallow the FAAAA’s preemption provision entirely. However, the Court disagreed. The exception saves only a subset of preempted claims, namely those involving motor vehicle safety. For example, many state laws related to motor carrier prices, routes, and services have no safety component. Those laws remain preempted. Rules about how much a carrier may charge or which highways it may use for purely economic reasons are good examples.
Next, the broker argued that Mr. Montgomery’s reading creates surplusage. In particular, the FAAAA contains other carveouts for size, weight, and hazardous-cargo rules. The Court acknowledged some overlap. However, it explained that any redundancy flows from the reference to “safety,” not from the phrase “with respect to motor vehicles.” Moreover, route and weight controls can serve non-safety goals. Examples include preventing wear on highways and protecting bridges.
Finally, the broker pointed to a structural anomaly. Subsection (b) of the FAAAA preempts state regulation of intrastate broker services. Unlike subsection (c), it contains no safety exception. Why, the broker asked, would Congress allow state safety claims against brokers for interstate shipments but preempt them for intrastate shipments? The Court conceded the puzzle. However, it declined to rewrite the statute. In its words, it was “better to live with the mystery than to rewrite the statute.” In short, the text of subsection (c)(2)(A) controls.
Justice Kavanaugh’s Concurrence
Justice Brett Kavanaugh, joined by Justice Samuel Alito, wrote separately. He stressed that the case was closer than the majority opinion might suggest. In particular, he credited the broker’s structural arguments. He also noted that federal law mandates minimum insurance for carriers but not for brokers.
Even so, the overall design of the FAAAA tipped the scales for him. In 1994, Congress pursued economic deregulation of trucking. It did not pursue safety deregulation. As a result, reading the statute to strip away state negligence claims against brokers, while leaving identical claims against carriers intact, would be too clever. Furthermore, federal law currently imposes essentially no meaningful safety duties on brokers when they choose carriers. It is unlikely that Congress meant to leave brokers in a regulatory void.
At the same time, Justice Kavanaugh offered a measured note for industry. The decision should not be read as a guarantee that brokers will routinely face liability after a truck crash. For example, brokers that vet carriers, review safety ratings, and ask the right questions should be well positioned to defend these claims. In addition, traditional proximate-cause principles will protect brokers when their conduct did not actually cause the harm.
Why Montgomery v. Caribe Transport Matters for Crash Victims
Crashes involving large trucks often produce catastrophic injuries. According to the FMCSA’s most recent Large Truck and Bus Crash Facts, thousands of deaths and over 100,000 injuries occur each year. The National Highway Traffic Safety Administration tracks similar trends in its annual crash statistics. Behind those numbers are real families dealing with medical bills, lost income, and long recoveries.
Before Montgomery, the law varied widely. In some regions, victims could not even bring a negligent-hiring claim against a broker. In other regions, the same claim could move forward. After this decision, the rule is the same nationwide. The FAAAA’s safety exception covers negligent-hiring claims against brokers. In addition, the trucks at the center of those claims fall within the states’ traditional safety authority. As a result, victims and their families benefit from a clear and consistent legal framework. The decision also helps level the playing field with large national companies that previously relied on preemption to avoid the merits.
Practical Implications for Brokers and the Industry
For brokers, the practical message is clear. Careful carrier selection matters. For example, brokers should review FMCSA safety ratings. They should also check inspection records and crash histories. In addition, they should avoid carriers with obvious red flags. As a result, brokers that follow these steps will be in a stronger position to defend negligent-hiring claims. In contrast, brokers that treat carrier selection as a purely commercial exercise now face a clearer path to potential exposure. Industry groups such as the Transportation Intermediaries Association are likely to update their best-practice guidance.
The decision also aligns broker accountability with carrier accountability. Trucking companies already face state-law claims when an unsafe truck or unfit driver causes a crash. Now, Montgomery confirms that brokers can face the same general standards of reasonable care. As a result, the decision rewards diligence. It also discourages willful blindness when public safety records are easy to find.
How Montgomery Could Affect Maryland and D.C. Cases
Maryland and the District of Columbia have their own legal rules that interact with federal trucking law. For example, both jurisdictions follow a strict contributory-negligence framework. As a result, full preparation of a truck case is especially important. The Montgomery decision does not change these state-specific principles. However, it helps ensure that all responsible parties in the chain of transportation can be considered.
In our region, commercial trucks move constantly along I-95, I-495, I-270, the Baltimore-Washington Parkway, and other major routes. When a crash happens, the company name on the trailer is often only the start of the story. The shipper, the broker, the leasing company, and even loading facilities can play a role. After Montgomery, broker conduct is squarely on the list of issues that can be examined in serious truck crash cases.
If you are weighing your options after a serious crash, we have several resources you may find helpful. For example, you can learn more on our pages discussing Maryland truck accident cases, Maryland personal injury claims, and Washington, D.C. personal injury law. Each case turns on its own facts. Outcomes vary widely based on the evidence and the law that applies.
Key Takeaways from Montgomery v. Caribe Transport II
The Supreme Court’s decision is unanimous. Its textual reasoning is narrow, but its real-world impact is broad. In short, it confirms three things. First, the FAAAA preempts state economic regulation of trucking and brokerage. However, it does not displace traditional state-law duties of care that protect the public from unsafe vehicles. Second, the phrase “with respect to motor vehicles” is read using ordinary English, consistent with prior cases. Third, brokers that arrange transportation with unsafe carriers cannot use federal preemption as a categorical shield.
For more context on how the courts of appeals had divided before this decision, several sources are useful. For instance, the Seventh Circuit and Ninth Circuit opinions discussed in Montgomery remain valuable reading. In addition, coverage from outlets such as Reuters Legal and Law360 has analyzed the practical fallout for shippers, brokers, and carriers.
What Victims Can Do After a Truck Crash
Certain steps in the hours and days after a serious commercial truck crash can affect the outcome of a case. First, get medical attention promptly. Do this even if injuries seem minor at first. Next, photograph the scene, the vehicles, and any visible markings on the truck. In addition, keep copies of the police report, medical records, and any insurance correspondence. Avoid giving recorded statements to insurance representatives before you speak with a lawyer. Finally, save names and phone numbers of any witnesses. Their accounts can prove valuable later.
For families dealing with the worst-case scenario, our wrongful death overview explains the legal framework that may apply. For crashes involving other passenger vehicles, our car accident page provides general background. However, none of this material is a substitute for advice tailored to your specific facts. It can simply help you understand the landscape before you speak with counsel.
Talk to a Truck Accident Lawyer Serving D.C. and Maryland
Truck and tractor-trailer collisions involve unique legal and factual issues. These include federal safety regulations, electronic logging data, and maintenance histories. Now, after Montgomery, broker hiring practices can also be part of the case. As a result, identifying every potentially responsible party often requires prompt investigation. In addition, some evidence can disappear or be overwritten within days of a crash.
If you or a loved one has been injured in a crash involving a commercial truck, the attorneys at Gelb & Gelb, P.C. are available to discuss your situation in a free, confidential consultation. You can contact our office. You can also learn more about our team on our attorney profiles page. Whether you are in the District of Columbia, Prince George’s County, or elsewhere in Maryland, we are happy to answer general questions about the legal process. In addition, you can browse our blog for more articles on trucking, insurance, and personal injury topics in our region.
This article is attorney advertising and is intended for general informational purposes only. It does not constitute legal advice and does not create an attorney-client relationship. Prior results do not guarantee a similar outcome in any future case. Every case depends on its own facts and applicable law. If you have a specific legal question, please consult a licensed attorney in your jurisdiction.
