The Court’s decision in Montgomery v. Caribe Transport II, LLC may determine whether injured people can bring state-law negligent-hiring claims against freight brokers that hire unsafe motor carriers.
By: Ross Karsnitz
The U.S. Supreme Court is reviewing a trucking-liability issue with practical consequences for people injured in serious commercial vehicle crashes. In Montgomery v. Caribe Transport II, LLC, the Court is considering whether federal law prevents state-law claims against freight brokers for negligently selecting a motor carrier or driver. The Court granted review on October 3, 2025, and heard argument on March 4, 2026.
Recent national reporting has drawn attention to a broader concern: serious truck crashes may involve not only the driver behind the wheel, but also the companies that select, hire, route, or profit from carriers operating on public roads. That question is now before the Supreme Court in a narrower legal form: whether freight brokers can face state-law negligent-selection claims when a carrier they hire is involved in a crash.
The question before the Court is narrow, but important: whether 49 U.S.C. § 14501(c) preempts a state common-law claim against a broker for negligently selecting a motor carrier or driver.
For people injured in truck crashes, that issue matters because commercial trucking cases often involve more than the conduct of one driver. A serious crash may require investigation into the driver, the motor carrier, the condition of the vehicle, maintenance records, hours-of-service compliance, dispatch practices, cargo loading, insurance coverage, and the companies involved in brokering the shipment.
In Delaware, truck crashes are not rare. According to Delaware’s 2024 Annual Traffic Statistical Report, the state recorded 2,245 truck-involved crashes in 2024. Those crashes included 12 fatal crashes, 529 injuries, and 12 deaths.
Those numbers sit within a broader roadway-safety concern. Delaware reported 27,660 traffic crashes in 2024, resulting in 132 deaths and 7,626 injuries. New Castle County had the highest number of traffic deaths in 2024, with 67 deaths, followed by Sussex County with 35 and Kent County with 30.
The risk is not limited to one kind of road or one part of the state. Delaware’s commercial corridors connect local roads with I-95, Route 1, Route 13, Route 40, the Port of Wilmington, distribution centers, beach traffic, and regional freight routes serving Pennsylvania, New Jersey, Maryland, and the broader Mid-Atlantic. When a large truck is involved in a crash, the consequences can be severe because of the size and weight of the vehicle, the complexity of the business relationships behind the shipment, and the number of entities that may have played a role before the truck ever entered the roadway.
Broker Liability Matters
Freight brokers do not typically drive the trucks. Their role is to arrange transportation by selecting motor carriers to move goods. The legal question in Montgomery is whether injured people can use state tort law to challenge a broker’s selection of a carrier when that selection allegedly contributed to a crash.
If the Supreme Court rules that federal law preempts these claims, it could limit the ability of injured people to pursue certain negligent-selection claims against brokers. If the Court allows those claims to proceed, freight brokers may continue to face state-law accountability when the facts support a claim that they failed to use reasonable care in selecting a carrier.
Either way, the decision will not eliminate the need for a careful investigation after a truck crash. It will make early evidence preservation even more important.
What Should be Investigated After a Serious Delaware Truck Accident?
After a crash involving a tractor-trailer, box truck, commercial van, or other large commercial vehicle, key questions may include:
- Who owned, operated, loaded, maintained, or dispatched the vehicle?
- Was the driver properly licensed, trained, and supervised?
- Did the motor carrier have a history of safety violations or crashes?
- Were hours-of-service, inspection, maintenance, or logbook requirements followed?
- Was a freight broker involved in selecting the carrier?
- What insurance policies may apply?
- Was electronic data available from the truck, dash camera, GPS system, or onboard telematics?
- Were there prior warning signs that the carrier or driver posed a safety risk?
These questions matter because truck crash cases can turn on evidence that is controlled by companies, not by the injured person. Acting quickly can help preserve records before they are lost, overwritten, or destroyed.
Truck Accidents in Delaware
Delaware’s crash data shows the heaviest fatality burden in New Castle County, but serious truck crashes can occur across the state, especially on commercial and commuter corridors that connect Delaware to Pennsylvania, New Jersey, Maryland, ports, distribution centers, and beach traffic. Because truck crashes often involve regional freight movement, determining responsibility may require looking beyond the crash scene.
