The U.S. Supreme Court ruled unanimously on May 14 that a man who lost a leg in a traffic accident may sue the logistics company that was involved in hiring the truck driver who hit him.
Justices held that federal law does not insulate freight brokers from state negligence lawsuits when they contract unsafe trucking companies.
The decision could have an impact on the trucking industry, exposing freight brokers to liability they previously thought they were shielded from by federal law.
The ruling was not on the merits of the man’s lawsuit, but it allows him to move forward in the lower courts.
The petitioner, Shawn Montgomery, experienced severe, permanent injuries after his tractor trailer was hit by a truck operated by someone who was driving a load of plastic pots through Illinois on behalf of the respondent, Caribe Transport.
Montgomery’s leg was surgically amputated. Another respondent, C.H. Robinson Worldwide Inc., a transportation broker, had arranged the shipment.
Montgomery sued all the respondents in federal district court, arguing that C.H. Robinson was responsible for his injuries, because it allegedly negligently hired the driver and Caribe Transport.
Montgomery argued that C.H. Robinson knew—or should have known—from Caribe Transport’s spotty safety rating that hiring it to transport goods was reasonably likely to lead to crashes that would injure others, according to the opinion.
The district court held that the Federal Aviation Administration Authorization Act—which preempts, or supersedes, state laws regulating prices, routes, and services provided by the trucking industry, specifically preempted Montgomery’s negligent hiring lawsuit.
The court also found that the lawsuit was not covered by the act’s safety exception, which states that the act’s preemption provision “shall not restrict the safety regulatory authority of a state with respect to motor vehicles.”
The U.S. Court of Appeals for the Seventh Circuit affirmed.
“The Federal Aviation Administration Authorization Act preempts state laws related to the prices, routes, and services of the trucking industry,” Barrett said.
But it provides an exception allowing states to regulate safety “with respect to motor vehicles,” she said.
“This case presents the question whether a claim that one company negligently hired another to transport goods falls within that exception. It does.”
Barrett said the justices agreed with Montgomery’s argument that even if the act preempts his negligent hiring lawsuit, the safety exception “saves it.”
Congress crafted the safety exception “to ensure that its preemption of states’ economic authority over motor carriers of property [did] ‘not restrict’ the preexisting and traditional state police power over safety,” she added.
The Supreme Court reversed the judgment of the Seventh Circuit and returned the case to that court for “further proceedings consistent with this opinion.”