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Montgomery Compliance · ·

Montgomery v. Caribe Transport II: What the Court Decided

The Supreme Court's May 2026 broker-negligence ruling, what it did not decide, and the records a broker should discuss with counsel.

By Freight Radar HQ. This guide explains public records and practical checks; it does not assess a specific carrier or provide legal advice.


The holding: on May 14, 2026, the Supreme Court held that the Federal Aviation Administration Authorization Act (FAAAA) does not preempt the state-law negligent-hiring claim against the broker in this case because the claim falls within the statute’s motor-vehicle safety exception. The Court reversed the Seventh Circuit and sent the case back. It did not decide that the broker was negligent.

Read the Court’s opinion and docket before relying on a summary. This guide is educational, not a substitute for advice about a particular claim or jurisdiction.

What happened

Shawn Montgomery was injured in a collision involving a driver for Caribe Transport II, a carrier selected for the shipment by C.H. Robinson. Montgomery alleged that the broker negligently selected the carrier, pointing in part to an alleged conditional FMCSA safety rating and deficiencies in the carrier’s record. Those are allegations described in the opinion, not findings by the Supreme Court that the broker knew of them or caused the crash.

The legal question at this stage was whether federal law blocked the state-law claim from proceeding. The FAAAA generally limits state regulation related to broker services but preserves a state’s safety regulatory authority with respect to motor vehicles. The Court held that this safety exception covered the negligent-hiring claim at issue.

What the ruling does not tell a broker

  • It does not make every broker liable when a carrier has a crash.
  • It does not announce a universal checklist or say that a conditional safety rating alone forbids booking.
  • It does not decide whether Montgomery will prove negligence or causation after remand.
  • It does not make a clean FMCSA snapshot a guarantee of safe operation.

Those distinctions matter. A page that jumps from “the claim may proceed” to “this exact file will protect you” promises more than the opinion provides.

A practical response

Review your carrier-selection policy with transportation counsel. Make sure the people booking freight can explain which source they check for identity, authority, insurance, safety rating, and current out-of-service status, and what they do when a result needs follow-up. Record the source, time, result, and decision for the particular load. An explanation for proceeding with a carrier should reflect the actual facts available at the time, not a stock phrase.

Our booking sequence and recordkeeping guide are operational starting points. They are not a legal safe harbor. FMCSA’s Company Snapshot is a primary place to review the carrier’s public safety information.

Source and scope: the legal outcome above comes from the Supreme Court’s opinion. The recordkeeping suggestions are Freight Radar HQ’s practical recommendations. Ask counsel how the decision applies to your contracts, claims, and state law.

Found an outdated source or a factual error? Tell us what needs correcting.

Source: FMCSA census & licensing data, refreshed daily Not affiliated with the FMCSA