Montgomery v. Caribe Transport II, LLC

608 U. S. 219 (2026) · 5/14/26

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. 49 U. S. C. §14501(c)(2)(A).

Petitioner Shawn Montgomery sustained severe and permanent injuries after his tractor trailer was struck by a truck driven by respondent Yosniel Varela-Mojena. Varela-Mojena was driving a load of plastic pots through Illinois for respondent Caribe Transport II, LLC, a motor carrier. Respondent C.H. Robinson Worldwide, Inc.—a transportation broker—had coordinated the shipment. Montgomery sued all respondents in Federal District Court and alleged, among other things, that C.H. Robinson was liable for his injuries because it negligently hired Varela-Mojena and Caribe Transport. Montgomery…

Held: A claim that one company negligently hired another to transport goods is not preempted by the FAAAA because States retain authority to regulate safety “with respect to motor vehicles” under the Act. Pp. 225–229. (a) Even if the FAAAA otherwise preempts Montgomery's negligent- hiring claim against C.H. Robinson, the safety exception saves it. The relevant text provides that the FAAAA's preemption provision “shall not restrict the safety regulatory authority of a State with respect to motor vehicles.” § 14501(c)(2)(A). All agree that common-law duties and standards of care form part of a…