Supreme Court Addresses Conflicts Between Federal and State Law Regarding Negligent Hiring Claims Against Freight Brokers

This case arises from a collision on an Illinois highway between a motorist and a tractor-trailer operated by a driver employed by the defendant, Caribe. The plaintiff brought suit, alleging a variety of claims, including negligent hiring and vicarious liability. However, rather than limit the application of negligent hiring to Caribe, the plaintiff attempted to extend this argument to the defendant freight broker, C.H. Robinson Worldwide by arguing that Robinson had negligently selected Caribe as the freight carrier.

Robinson moved to dismiss the negligent hiring claims pursuant to Section 14510(c)(1) of the Federal Aviation Administration Authorization Act of 1994, as the language of that statute prohibits state suits against brokers “relat[ing] to a price, route, or service” and “with respect to the transportation of property”. The District Court ruled in favor of the plaintiff, stating that the safety exception of Section 14501(c)(2)(A) permitted such claims, as it preserves “safety regulatory authority of a State with respect to motor vehicles.” On appeal, the U.S. Court of Appeals for the Seventh Circuit ruled in favor of defendant Robinson, ruling that “the FAAAA preempts state law claims that a freight broker negligently hiring a motor carrier.”

Given that a conflict presently exists between rulings on this issue from the U.S. Court of Appeals for the Sixth and Ninth Circuits and the U.S. Court of Appeals for the Seventh and Eleventh Circuits, the Supreme Court granted certiorari on October 3, 2025.

The Supreme Court heard oral argument on March 6, 2026, and has yet to issue a decision.