Montgomery v. Caribe Transport II

The Federal Aviation Administration Authorization Act (FAAAA) — a federal law that generally blocks states from regulating trucking industry prices, routes, and services — does not preempt state negligent-hiring lawsuits against transportation brokers, because those claims fall within the law's built-in safety exception preserving state authority to regulate motor vehicle safety. Justice Amy Coney Barrett authored the unanimous opinion of the Court. The FAAAA's preemption provision broadly blocks state laws "related to a price, route, or service" of motor carriers and brokers. But the safety exception carves back that prohibition: it "shall not restrict the safety regulatory authority of a State with respect to motor vehicles." State common-law duties — including negligent hiring, which requires a company to use reasonable care when selecting a contractor for dangerous work — qualify as exercises of that safety regulatory authority. The central question therefore becomes whether a negligent-hiring claim against a broker "concerns" motor vehicles, as the phrase "with respect to" ordinarily means. The FAAAA defines "motor vehicle" as trucks and trailers used on highways for transportation. A negligent-hiring claim against a broker directly concerns those vehicles: the whole point of hiring a carrier is to put trucks on the road, and requiring a broker to screen for carrier safety plainly concerns the trucks those carriers will operate. The safety exception does not collapse the preemption provision entirely. The exception rescues only a subset of claims — those tied to motor vehicle safety. Many state laws touching carrier prices, routes, or services have no safety connection and remain preempted. The broker's argument that this reading creates textual redundancy fails because any overlap stems from the word "safety" in the exception itself, not from the phrase "with respect to motor vehicles." The broker's separate argument — that a different FAAAA subsection preempts broker regulation for intrastate routes without any safety exception, creating an anomaly — cannot override the plain text of the safety exception in subsection (c)(2)(A). Justice Brett Kavanaugh concurred, joined by Justice Samuel Alito, agreeing with the result but emphasizing the case was closer than the majority suggested, noting that the FAAAA's mandatory insurance scheme and intrastate preemption provisions offered real textual support for the brokers' position, and that the outcome was ultimately driven by Congress's intent to pursue economic — not safety — deregulation, making it implausible that the law would simultaneously expose trucking companies to tort liability while shielding brokers from any such accountability.