What the Supreme Court’s Truck Accident Ruling Means

On May 14, 2026, the United States Supreme Court ruled 9 to 0 in Montgomery v. Caribe Transport II, LLC that the FAAAA’s motor-vehicle safety exception preserves the negligent-hiring claim against the freight broker in that case. The decision resolves the federal preemption issue. It does not establish that the broker was negligent or that insurance coverage is available.

Montgomery v. Caribe Transport Decision

Justice Amy Coney Barrett wrote the unanimous opinion. The Court held that Montgomery’s negligent-hiring claim falls within the FAAAA’s motor-vehicle safety exception, reversed the Seventh Circuit, and returned the case for further proceedings, according to the opinion.

The case turned on the Federal Aviation Administration Authorization Act, a 1994 law known as the FAAAA. Congress extended its preemption to brokers by a 1995 amendment. That law generally blocks states from regulating broker services, with one carve-out: states keep their authority over motor vehicle safety. The Court held that a negligent hiring claim about a broker’s choice of an unsafe carrier falls inside that carve-out under 49 U.S.C. § 14501(c)(2)(A).

Justice Kavanaugh, joined by Justice Alito, wrote separately. He called it a close case, but agreed that truck safety is a life-and-death issue and that liability gives brokers a strong incentive to do business only with safe and reliable carriers. He also noted that brokers who act with care and hire reputable carriers should be able to defend these suits.

Illinois Highway Crash Behind the Case

Shawn Montgomery’s tractor-trailer was stopped on the side of an Illinois highway when a truck hauling a load for Caribe Transport II, LLC veered off course and struck it. Montgomery’s leg had to be amputated, and he sustained other severe and permanent injuries. The shipment had been brokered by C.H. Robinson Worldwide, one of the largest freight brokers in the country.

Montgomery sued C.H. Robinson for negligent hiring. Caribe Transport had a conditional safety rating from the FMCSA when the broker hired it, and Montgomery alleged C.H. Robinson knew, or should have known, that choosing the carrier was likely to result in crashes that would injure others. The district court dismissed the claim as preempted by federal law, the Seventh Circuit affirmed, and the Supreme Court reversed.

Freight Broker Role in Carrier Selection

A freight broker finds a trucking company to haul a shipper’s load and takes a fee for making the match, and the broker’s choice of carrier is the conduct at issue in a negligent selection claim. The biggest brokers arrange millions of shipments a year. A full explanation of freight broker liability after a truck crash covers the statute in more depth.

More than 780,000 motor carriers operate in the United States, and roughly 28,000 brokers arrange transportation for about a third of all freight, according to FMCSA data cited in the Montgomery opinion. Carrier safety records are public and free to search. The FMCSA’s SAFER system shows safety ratings, operating authority, and out-of-service histories, and a broker can check them before every dispatch. A separate article explains how to read the FMCSA SMS report.

Circuit Split Over FAAAA Preemption

Before Montgomery, federal appeals courts disagreed about whether the FAAAA preempted negligent hiring claims against brokers. The Seventh Circuit’s 2023 decision in Ye v. GlobalTranz and the Eleventh Circuit’s decision in Aspen American v. Landstar Ranger shut these claims down before discovery began. The Sixth and Ninth Circuits allowed them. The Supreme Court agreed to resolve that split.

The broker is often the party with the most knowledge of the carrier’s safety record before the truck leaves the lot. In the circuits that followed Ye, the FAAAA preemption defense blocked these claims. Montgomery resolves the split by applying the motor-vehicle safety exception.

Insurance Gap in Trucking Cases

The federal minimum insurance for an interstate motor carrier is $750,000. The FMCSA puts the comprehensive cost of the average fatal large truck crash at more than $15 million in 2023 dollars.

Families dealing with traumatic brain injuries, spinal cord damage, amputations, or wrongful death have often recovered a fraction of their damages when the only reachable defendant was an undercapitalized carrier with minimum coverage. Kentucky’s own minimum insurance limits have not moved since 1974.

Montgomery removes a federal preemption barrier to negligent carrier-selection claims. A claim against a freight broker still depends on the facts and the applicable state-law requirements.

Negligent Broker Selection Red Flags

A negligent selection claim asks what the broker knew and what it checked. Red flags that can put a broker’s decision in front of a jury include:

• A conditional safety rating from the FMCSA
• Recent out-of-service orders
• Operating authority less than eighteen months old
• Elevated BASIC scores or a documented crash pattern

Attorneys can obtain the broker’s vetting policies, screening criteria, pre-dispatch communications, and the historical pattern of carriers the broker repeatedly hired. The absence of a documented vetting process is itself evidence.

Kentucky Freight Corridors and Crash Data

Four major interstate freight corridors cross Kentucky: I-65, I-64, I-71, and I-75. Three of them converge in Louisville, and I-75 runs through Lexington and the eastern part of the state.

Truck crash numbers follow the freight. Kentucky State Police data shows trucks were involved in 9,736 crashes in 2024. Ninety-nine of those crashes were fatal, accounting for about 15% of all fatal crashes statewide that year.

In Kentucky truck accident cases, the driver, carrier, and broker may each require investigation depending on the facts. The Sixth Circuit, which covers Kentucky, had already recognized the safety exception in Cox v. Total Quality Logistics in 2025, as the Court notes in footnote 1. Montgomery resolves the nationwide split. It does not create a new Kentucky cause of action or guarantee insurance coverage.

Broker Carrier-Selection Records

Montgomery adds the broker’s file to the records worth preserving after a truck crash. Spoliation letters already cover electronic logging device data, black box data, dashcam footage, driver qualification files, and maintenance records. After Montgomery, they can also reach the broker’s carrier selection records, the FMCSA safety data the broker had at the time of dispatch, and the broker’s documented vetting process.

A broker that dispatched a carrier with a conditional rating now has to explain that decision under oath. Montgomery removes the FAAAA preemption barrier addressed in the opinion, but negligence, causation, damages, and available coverage remain case-specific.