Freight brokers rely on motor carrier registration and safety information when deciding which companies to use for shipments.
The accuracy and interpretation of those records can become important when a carrier is involved in a serious crash.
That issue received national attention in Montgomery v. Caribe Transport II, LLC, a Supreme Court case involving allegations that a freight broker negligently selected an unsafe trucking company.
On May 14, 2026, the Supreme Court ruled unanimously that the relevant state-law negligent-hiring claim was not barred by federal preemption.
For brokers and carriers, the practical lesson is to verify information carefully and maintain accurate federal records.
What Was the Montgomery Case About?
In December 2017, Shawn Montgomery suffered serious injuries when a truck operated for Caribe Transport II struck his stopped tractor-trailer in Illinois.
C.H. Robinson Worldwide had arranged the shipment.
Montgomery alleged that the broker should have recognized safety concerns associated with the motor carrier before selecting it.
The dispute eventually reached the Supreme Court.
What Did the Supreme Court Decide?
The case involved the Federal Aviation Administration Authorization Act, or FAAAA.
That law generally preempts certain state laws affecting transportation prices, routes, and services.
It also preserves state safety regulatory authority concerning motor vehicles.
The Supreme Court held that the type of negligent-hiring claim brought against C.H. Robinson falls within that safety exception.
The Court reversed the Seventh Circuit and remanded the case.
The ruling did not determine whether C.H. Robinson was actually negligent.
Why Are USDOT Records Relevant?
A USDOT number identifies a transportation business in FMCSA’s registration system.
The associated record can provide information about company identity, operations, fleet size, and safety history.
Brokers often consult this information when evaluating a carrier.
Carriers should keep their records accurate because outdated information can create uncertainty about the business.
Step 1: Confirm the Carrier’s Identity
Verify the legal name and USDOT number of the motor carrier.
Compare those details with the carrier’s business documents and the proposed transportation agreement.
Look for unexplained inconsistencies in company identity or contact information.
If the record belongs to another entity, do not treat it as proof of the proposed carrier’s status.
Step 2: Review the SAFER Company Snapshot
FMCSA’s SAFER system provides a public Company Snapshot.
It may include the carrier’s legal name, operating information, safety rating if available, roadside inspection summaries, and crash information.
The snapshot is a starting point for review.
It is not a comprehensive guarantee of safety or legal compliance.
Step 3: Check Operating Authority
Confirm that the carrier has the appropriate authority for the transportation service being arranged.
FMCSA distinguishes between a company’s USDOT registration status and its operating authority status.
A business may have a USDOT number without authority to conduct a particular type of interstate for-hire transportation.
Use current official records rather than relying exclusively on older documents.
Step 4: Review Available Insurance Information
Check the insurance information relevant to the transportation arrangement.
Some federal insurance filings are associated with operating authority.
Brokers may also need to obtain appropriate insurance evidence directly from the carrier or its insurer.
A filing record does not necessarily answer every contractual coverage question.
Step 5: Understand the Carrier’s Safety Rating
A federal safety rating, when available, provides information about an FMCSA safety determination.
Not every carrier has a current safety rating.
An unrated carrier should not automatically be described as unsafe or safe.
Review the available information in context.
Step 6: Examine Inspection and Crash Information
Public inspection and crash data can help identify issues requiring further review.
Consider the age, severity, and nature of the available information.
A single inspection finding does not necessarily establish that a carrier is unfit.
Likewise, the absence of a particular violation does not guarantee safe future performance.
Step 7: Review MCS-150 Information
The MCS-150 maintains federal company information, including addresses, operating classifications, power units, drivers, and mileage.
An outdated filing can leave important details inaccurate.
Carriers should review whether reportable information changes require an update.
A routine MCS-150 filing does not erase valid safety violations or guarantee broker approval.
Step 8: Check Registration Status Separately From Authority
A carrier’s USDOT status and operating authority should be evaluated as distinct fields.
For example, FMCSA’s SAFER guidance distinguishes authorized, not authorized, and out-of-service authority conditions.
The meaning depends on the entity’s type of operation.
Private carriers and intrastate operations may not require the same authority as interstate for-hire carriers.
Step 9: Document Carrier-Selection Decisions
A broker may choose to maintain records showing when carrier information was checked and what information was considered.
Documentation can include official record references, dates, and follow-up questions.
The Supreme Court did not establish a universal federal documentation checklist.
A reasonable process should be tailored to the business and reviewed with appropriate counsel.
Step 10: Recheck Material Changes
A carrier’s authority, insurance, registration, and safety information can change.
A one-time review may become outdated.
Brokers should determine when additional checks are appropriate, particularly after receiving credible information about a material change.
Carriers should promptly address inaccurate records.
Step 11: Distinguish Registration Corrections From Safety Challenges
If a legal name, address, or fleet count is incorrect, the company should use the appropriate FMCSA registration update procedure.
If roadside inspection or crash data is believed to be inaccurate, the company may use the DataQs review process.
An MCS-150 filing does not remove a valid inspection.
A DataQs request does not automatically update the company’s registration information.
Step 12: Understand the Limits of the Supreme Court Ruling
The May 2026 decision allows the relevant type of negligent-hiring claim to proceed without being barred by the FAAAA’s general preemption rule.
It does not make every carrier-selection decision negligent.
It also does not require FMCSA to assign every carrier a safety rating.
The outcome of any individual lawsuit depends on its facts and applicable law.
What About Independent-Contractor Agreements?
The lower courts considered whether C.H. Robinson controlled Caribe Transport sufficiently to support vicarious liability.
They found the independent-contractor arrangement significant to that separate issue.
The Supreme Court did not decide that an independent-contractor clause defeats every negligent-selection claim.
Contract terms and actual business conduct should be reviewed together.
Does UCR Registration Prove a Carrier Is Safe?
No.
UCR is a separate annual registration and fee requirement for covered interstate transportation entities.
A UCR payment does not establish a favorable safety rating or guarantee that a carrier is qualified for every shipment.
USDOT registration, operating authority, safety information, and UCR must be considered separately.
Frequently Asked Questions
Did Montgomery create a new USDOT filing requirement?
No. It addressed federal preemption of a state-law negligent-hiring claim.
Can brokers use SAFER to review carriers?
Yes. The public Company Snapshot is a useful starting point.
Does an active USDOT number guarantee valid operating authority?
No. The statuses are separate.
Can an MCS-150 update remove safety violations?
No. Registration updates and safety data reviews are different processes.
Does the decision automatically make brokers liable for carrier accidents?
No. Liability must still be established under applicable law.
Should carriers maintain accurate public records?
Yes. Accurate records support registration compliance and informed business decisions.
Keep USDOT Information Current
Accurate registration information helps brokers, shippers, and other transportation partners understand the business they are evaluating.
MOTUS – MCS-150 Prepayment provides private assistance with USDOT registration records, MCS-150 updates, and related administrative matters.
Visit MOTUS – MCS-150 Prepayment or call (800) 924-1130 for assistance reviewing your USDOT company information.
MOTUS – MCS-150 Prepayment is a private third-party service and is not affiliated with FMCSA or the U.S. Department of Transportation. It does not provide legal representation or guarantee a carrier’s selection by brokers. This article is general information, not legal advice.
