Episode Description
Montgomery v. Caribe Transport II, LLC
Argued on Mar 4, 2026.
Petitioner: Shawn Montgomery.
Respondent: Caribe Transport II, LLC.
Advocates:
- Paul D. Clement (for the Petitioner)
- Theodore J. Boutrous Jr. (for the Respondents)
- Sopan Joshi (for the United States, as amicus curiae, supporting the Respondents)
Facts of the case (from oyez.org)
Shawn Montgomery was severely injured when his tractor-trailer, stopped on the shoulder of an Illinois highway, was struck by another truck. The other driver, Yosniel Varela-Mojena, was employed by the motor carrier Caribe Transport II, LLC (“Caribe”). C.H. Robinson Worldwide, Inc. (“Robinson”), a freight broker, had arranged for Caribe to haul the shipment. Robinson and Caribe operated under an agreement stating that Caribe was an independent contractor and retained exclusive control over its personnel and the manner of its performance.
Montgomery sued the driver and Caribe, and also sued the broker, Robinson. His claims against Robinson alleged that the broker was vicariously liable for the driver’s negligence, arguing Caribe was Robinson’s agent. Montgomery also claimed Robinson had negligently hired the driver and the carrier.
The district court granted judgment to Robinson on all claims. The U.S. Court of Appeals for the Seventh Circuit affirmed, holding that Caribe was an independent contractor, which defeated the vicarious liability claim, and that the Federal Aviation Administration Authorization Act preempted the state-law negligent hiring claim.
Question
Does 49 U.S.C. § 14501(c) preempt a state common-law claim against a broker for negligently selecting a motor carrier or driver?