The question
Whether a state-law claim that a transportation broker negligently hired a motor carrier to transport goods is preempted by the Federal Aviation Administration Authorization Act, or whether it is saved by the Act's exception for a State's safety regulatory authority with respect to motor vehicles.
Montgomery v. Caribe Transport II, LLC
What the Court decided
The Court reversed the Seventh Circuit and held that a claim that one company negligently hired another to transport goods is not preempted by the Federal Aviation Administration Authorization Act. The FAAAA's safety exception preserves a State's authority to regulate safety with respect to motor vehicles, and that phrase means a claim that concerns the vehicles used in transportation. Requiring a broker to exercise ordinary care in selecting a carrier concerns the trucks that will transport the goods, so the negligent-hiring claim falls within the safety exception and survives preemption.
How the justices split
UnanimousThe Court's opinion
Barrett, joined by Roberts, Thomas, Alito, Sotomayor, Kagan, Gorsuch, Kavanaugh, Jackson
The safety exception preserves state common-law duties, including the duty of reasonable care underlying a negligent-hiring claim. Because the FAAAA does not define the phrase with respect to motor vehicles, the Court gives it its ordinary meaning of concerns, consistent with Dan's City Used Cars v. Pelkey. A negligent-hiring claim against a broker concerns the trucks that will transport the goods, so it is with respect to motor vehicles and the safety exception saves it. The exception saves only the subset of preempted claims involving motor vehicle safety, and state laws related to carrier prices, routes, and services with no relationship to safety remain preempted.
Concurring
Kavanaugh, joined by Alito
Kavanaugh filed a concurring opinion, joined by Alito. The syllabus does not state the grounds of the concurrence.
How we know · 5 sourced claims
The FAAAA expressly preempts state laws related to the prices, routes, and services of the trucking industry under 49 U.S.C. 14501(c)(1).
Source: syllabus, Held
The FAAAA's safety exception provides that the preemption provision shall not restrict the safety regulatory authority of a State with respect to motor vehicles.
Source: syllabus, Held
The Court construed the phrase with respect to motor vehicles to mean concerns the vehicles used in transportation, following Dan's City Used Cars, Inc. v. Pelkey.
Source: syllabus, Held
Barrett delivered the opinion for a unanimous Court, and Kavanaugh filed a concurring opinion in which Alito joined.
Source: syllabus, lineup
The safety exception saves only a subset of preempted claims, and state laws related to carrier prices, routes, and services with no relationship to safety remain preempted.
Source: syllabus, Held