“Montgomery claimed that C.H. Robinson knew (or should have known) from Caribe Transport’s safety rating that hiring it to transport goods was reasonably likely to result in crashes that would injure others.”
The Supreme Court ruled on Thursday that the federal law does not shield transportation brokers from state negligence lawsuits over hiring unsafe trucking companies. The court held that "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."
The case was brought forth by Shawn Montgomery, who sustained "serious and permanent injuries" after his tractor-trailer was hit by a truck driven by respondent Yosniel Varela-Mojena in Illinois. Varela-Mojena had been hired by the motor carrier Caribe Transport II, LLC, and the broker C.H. Robinson Worldwide, Inc had coordinated the shipment.
Montgomery sued the companies, alleging that C.H. Robinson was liable for his injuries "because it negligently hired Varela-Mojena and Caribe Transport. Montgomery claimed that C.H. Robinson knew (or should have known) from Caribe Transport’s safety rating that hiring it to transport goods was reasonably likely to result in crashes that would injure others."
The court’s opinion, delivered by Justice Amy Coney Barrett, stated, "The Federal Aviation Administration Authorization Act preempts state laws related to the prices, routes, and services of the trucking industry. But there is an important exception: States retain authority to regulate safety “with respect to motor vehicles.” This case presents the question whether a claim that one company negligently hired another to transport goods falls within that exception. It does."
It explained, "Sellers often use motor carriers to transport products to their destination. But finding a carrier can be time-consuming, so many sellers rely on brokers to do it for them. Think of it this way: Brokers are the transportation industry’s matchmakers, connecting sellers of goods to the carriers who move them. Today, roughly 28,000 brokers arrange transportation for about a third of all freight shipped in the United States by more than 780,000 carriers. Brokers net the difference between the price that a company will pay to move goods and the cost of hiring a carrier."
In the accident, the truck driven by Varela-Mojena veered out of it’s lane, striking a truck, driven by Montgomery, which had been stopped on the side of the road. As a result, Montgomery’s leg was amputated, and he has suffered other lasting injuries. Varela-Mojena had been driving for Caribe Transport, and C.H. Robinson had coordinated the shipment.
Caribe Transport had a "conditional" rating from the Federal Motor Carrier Safety Administration when it was hired by C.H. Robinson, with the agency finding the transportation company to be deficient "with respect to qualification of drivers," "hours of service of drivers," "inspection, repair, and maintenance," "recordable crash rate," and other deficiencies. Montgomery argued that due to the rating, C.H. Robinson should have known that selecting the company for transport "was reasonably likely to result in crashes that would injure others."
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