On May 14th, 2026, the Supreme Court made a unanimous decision holding that the Federal Aviation Administration Authorization Act of 1994 (FAAAA) does not bar the type of negligent-hiring claim declared in the case because the claim falls within the Motor Vehicle Safety exception. Understanding this Supreme Court ruling and what it ultimately means for accident claims is important and necessary for the future.
Montgomery v. Caribe Transport II: An Overview
Shawn Montgomery's tractor-trailer was stopped along the highway when another tractor-trailer hit it. Montgomery suffered severe and permanent injuries, including the amputation of his leg.
Montgomery later on sued several parties. His claim against the broker implied negligent hiring or selection. Specifically, he alleged that the broker knew or should have known that Caribe Transport presented safety concerns when it was selected to haul the shipment.
Understanding Federal Preemption
The FAAAA usually restricts states from implementing laws related to the following.
- Prices
- Routes
- Services
Freight brokers have depended on this federal preemption provision when arguing that state negligent-selection claims against them should be disregarded. However, the FAAAA also contains an important exception. Federal preemption does not restrict a state's safety regulatory authority "with respect to motor vehicles."
The Supreme Court ultimately decided that Montgomery's negligent-hiring claim fit within this safety exception. The Court explained that requiring a freight broker to exercise ordinary care when selecting a motor carrier affects motor vehicles because the carrier's trucks will eventually transport the goods.
Freight Brokers
The decision resolves a disagreement that had developed among federal appellate courts over whether the FAAAA preempted these types of negligent-hiring claims against freight brokers.
Following Montgomery, an injured person may be able to pursue a state-law claim alleging that a broker failed to use reasonable care when selecting a motor carrier, depending on the applicable state law and the circumstances of the accident.
Commercial Trucking
Commercial trucking usually includes several separate businesses. A shipper may hire a freight broker, which then arranges transportation through an independent motor carrier. The carrier may employ or contract with the driver who physically transports the shipment.
As a result of this structure, determining responsibility after a truck collision can be challenging and often involves more than examining the driver's actions immediately before the crash. When negligent-selection allegations are available, relevant evidence may include, but is not limited to, the following:
- The carrier’s safety information
- Operating history
- Prior violations
- Inspection history
- Qualifications
- Regulatory status
- Other information that may have been available when the broker selected the specific carrier.
Individuals Who May Suffer Injuries
For people injured in commercial truck collisions, Montgomery may affect how potential responsible parties are evaluated. Depending on the circumstances, a truck accident investigation may consider the conduct of the driver and motor carrier as well as the role of a freight broker involved in arranging the shipment.
For example, questions may arise about what information was available when a carrier was selected, whether there were identifiable safety concerns, what procedures the broker used to evaluate the carrier, and whether those circumstances relate to the collision.
A broker's involvement alone does not establish negligence. Each potential claim requires an individual assessment of the evidence, applicable state negligence law, causation, damages, and available defenses.
Seeking the Help of a Legal Professional
Truck accident cases can involve substantial amounts of evidence, including driver qualification records, electronic logging data, inspection and maintenance documents, communications between transportation companies, shipping agreements, insurance information, and government safety records.
Evidence may also help identify the relationships among the shipper, broker, carrier, driver, and other entities involved in transporting the load. Following the Supreme Court's decision in Montgomery, attorneys evaluating certain commercial trucking accidents may also examine the freight broker's carrier-selection process where the facts and applicable state law support doing so.
The Legal Team at KAASS LAW
The legal team at KAASS LAW may be able to help victims and individuals with personal injury matters, including claims arising from commercial vehicle and truck accidents. When appropriate, a qualified personal injury attorney can review available accident records, identify potentially involved parties, examine insurance information, and evaluate whether the facts may support claims under applicable law. In a commercial trucking matter, this may include, but is not limited to, the following.
- Reviewing the respective roles of the truck driver, motor carrier, freight broker, and other businesses connected to the shipment
If you or a loved one has been involved in an accident with a truck driver, you are not alone. KAASS LAW is here to help. Call us today to receive a confidential consultation and to learn more about your rights and responsibilities during your personal injury case.