Montgomery v. Caribe Transport: The Future Verdict of Holding Freight Brokers Accountable

The Facts of the Accident

On December 7, 2017, Shawn Montgomery sustained severe injuries when his parked tractor-trailer was struck by another truck on an Illinois highway shoulder. The vehicle that struck Montgomery’s tractor-trailer was operated by Yosniel Varela-Mojena, an employee of Caribe Transport, a motor carrier contracted by the freight brokerage firm C.H. Robinson Worldwide. 

Shawn Montgomery claims that C.H. Robinson hired an unsafe carrier, leading to the accident. Montgomery attempted to sue both the broker and the carrier, stating that C.H. Robinson was liable for the driver’s negligence. 

In 2025, Montgomery brought a negligence claim in court, seeking to sue all three parties involved in the accident (the broker, the carrier, and the driver). 

The Verdict of the Lower Court

The question raised in the lower Court was whether freight brokers could be held liable under state law for accidents caused by motor carriers they hire. Montgomery alleged that C.H. Robinson is vicariously liable for the torts of both the driver and the carrier, and that they hired the driver and carrier negligently.

These claims formed the basis of the lawsuit, in which the district court granted partial summary judgment in favor of C.H. Robinson, dismissing the negligent-hiring claims. The ruling was based on Seventh Circuit precedent, holding that the FAAAA preempts state-law negligent-hiring claims against freight brokers. 

Overall, an agreement between C.H. Robinson and Caribe Transport, which stated that Caribe was an independent contractor and retained exclusive control over its employees, led to the defendant being granted partial summary judgment. Due to this signed agreement, the claim of vicarious liability could not support the lawsuit.

C.H. Robinson and Caribe Transport sequentially followed their Broker/Carrier Agreement, which stated that Caribe would act as Robinson’s independent contractor rather than as an agent, and such designations cannot be overlooked.

Additionally, in deciding against finding vicarious liability, the Court highlighted the following 

Items of interest: 

• C.H. Robinson did not supply or maintain Caribe Transport’s equipment; 
• C.H. Robinson did not select the driver, the route, the hours of service, or the locations for rest and fueling stops. 
• C.H. Robinson did not make any hiring or firing decisions for Caribe Transport; Robinson did not pay drivers or even make direct payments to Caribe for the loads, nor did it withhold taxes or benefits from these payments. 
• C.H. Robinson did not offer drivers any training, manuals, or uniforms.
• Either party could end the relationship at any time.

For these reasons, the Court of Appeals determined that Caribe Transport and its driver were independent contractors of C.H. Robinson. Consequently, vicarious liability could not be imposed on C.H. Robinson.

Heading to the Supreme Court

Although the lower Court ruled against vicarious liability for C.H. Robinson, various federal circuit courts have reached conflicting conclusions. On October 3, 2025, the Supreme Court agreed to review the case to set a precedent and provide clarity on liability for carrier accidents moving forward.

The oral argument is scheduled for March 4, 2026, before the U.S. Supreme Court. Although the final decision has yet to be announced, recent filings indicate that the U.S. Department of Justice urges preemption of these state tort claims. 

The Current Administration’s Standpoint

At this point, the current administration appears to support preemption, stating that the FAAAA shields brokers from state tort claims alleging negligent hiring of unsafe motor carriers. 

The current administration is signaling an intention to uphold the nationwide framework enacted in 1994. The main purpose of backing the brokers in this case is to protect prices, routes, and services that would otherwise be affected by a change in liability standards.

The current administration argues that allowing state-level negligence lawsuits against brokers undermines federal authority, which currently supports the view that brokers should be recognized as intermediaries, not the source of liabilities for negligent motor carriers that they hire.

The Significance of the Verdict for the Trucking Industry

This ruling seeks to establish a clear precedent on whether the FAAAA of 1994 preempts state-level negligence claims. This clarity will provide the industry with a uniform standard for broker liability. If the verdict finds brokers liable, broker liability and insurance costs are expected to skyrocket, creating a bottleneck for the industry. Not only will costs be passed down to shippers and consumers, but capacity constraints are likely if brokers decide to exit the industry due to the high risk. 

Additionally, small carriers with lower safety ratings may find it challenging to secure loads from large brokers, as these brokers implement higher vetting standards to mitigate risk and find themselves with few recourse options. 

Overall, the outcome of this case will fundamentally change how brokers manage risk and select carriers and shipments, thereby altering the entire freight industry landscape. The Supreme Court’s decision is expected to be released by the summer of 2026.