Montgomery v. Caribe Transport II, LLC
The Court holds that a state common-law negligent-hiring claim against a transportation broker is not preempted by the Federal Aviation Administration Authorization Act, because the Act's safety exception preserves state authority to regulate motor-vehicle safety — including the ordinary-care duty owed by those who choose which carrier will move goods on the highway.
Opinion: https://www.supremecourt.gov/opinions/25pdf/24-1238_1b7d.pdf
Case background
Shawn Montgomery sustained severe and permanent injuries when his tractor-trailer was struck on the side of an Illinois highway by a truck driven by Yosniel Varela-Mojena, who was hauling a shipment for motor carrier Caribe Transport II, LLC. C.H. Robinson Worldwide, Inc., a transportation broker, had coordinated that shipment. Montgomery sued, alleging that C.H. Robinson was liable for his injuries because it negligently hired Varela-Mojena and Caribe Transport despite a “conditional” safety rating from the Federal Motor Carrier Safety Administration. The district court held the negligent-hiring claim was expressly preempted by the Federal Aviation Administration Authorization Act and did not fall within the Act’s safety exception, and the Seventh Circuit affirmed.
Questions Presented
- Does § 14501(c) preempt a state common-law claim against a broker for negligently selecting a motor carrier or driver?
Holding
A claim that one company negligently hired another to transport goods is not preempted by the Federal Aviation Administration Authorization Act, because States retain authority to regulate safety with respect to motor vehicles under the Act. Requiring a broker to exercise ordinary care in selecting a carrier “concerns” motor vehicles — most obviously the trucks that will transport the goods — and so falls within the Act’s safety exception, which saves it from preemption.
The Court
Justice Barrett delivered the opinion for a unanimous Court. Justice Kavanaugh filed a concurring opinion, in which Justice Alito joined.
What this episode contains
This episode is an AI-narrated reading of the majority opinion in Montgomery v. Caribe Transport II, LLC, written by Justice Barrett.
AI disclosure: The voice in this episode is AI-generated, using a machine learning model styled to loosely resemble the authoring justice. Tone, inflection, pacing, and emphasis are artifacts of the model and should not be attributed to Justice Barrett. The text being read is the Court’s published majority opinion, lightly adapted to improve readability for the spoken format.