Montgomery v. Caribe Transport II, LLC, et al., 608 U.S. __, 2026 WL 1336188 (2026)
A motor carrier was hired by a transportation broker to transport goods. An employee of the motor carrier struck and injured the plaintiff while trucking a load of goods. Plaintiff sued, alleging that the transportation broker knew or should have known that hiring the motor carrier was likely to result in accidents. The District Court held the Federal Aviation Administration Authorization Act (“FAAAA”) preempted plaintiff’s negligent hiring claim. The Seventh Circuit affirmed. The Supreme Court granted certiorari to resolve a split of authority on this issue.
The Supreme Court reversed, holding that state law negligent hiring claims are not preempted by the FAAAA because such claims fall within the safety exception to the FAAAA’s preemption provision. “[T]he safety exception provides that the preemption provision ‘shall not restrict the safety regulatory authority of a State with respect to motor vehicles.’ [49 U.S.C.] §14501(c)(2)(A).” The Court noted that “Congress designed the safety exception ‘to ensure that its preemption of States’ economic authority over motor carriers of property [did] ‘not restrict’ the preexisting and traditional state police power over safety.’” Following ordinary dictionary meaning, the Court concluded that the phrase “with respect to motor vehicles” in the safety exception means “concerns” or “regards” and that therefore “a claim is ‘with respect to motor vehicles’ if it ‘concerns’ or ‘regards’ the vehicles used in transportation.” Accordingly, the Court held that, because the transportation broker “failed to exercise reasonable care when it hired [the motor carrier]” and [r]equiring [the transportation broker] to exercise ordinary care in selecting a carrier . . . “concerns” motor vehicles,” plaintiff’s negligent hiring claim “falls within the FAAAA’s safety exception, which saves it from preemption.”
