11th Circuit Rules That Brokers Are Not Liable for Negligent Hiring in Truck Accident Lawsuits

A fatal Georgia truck crash led to a major federal court dispute over whether a freight broker can be sued for allegedly hiring an unsafe trucking company.

In 2020, the family of a Georgia man who died in a fatal trucking accident filed a wrongful death lawsuit against the truck driver, the trucking company that owned the tractor-trailer, and Total Quality Logistics, the freight broker that arranged for the transportation of the company’s goods.

The underlying crash occurred after a tractor-trailer made a U-turn on State Route 73 and obstructed traffic in both directions. The decedent’s vehicle collided with the truck, and he later died from his injuries. The family’s claims against the freight broker created an important legal dispute over whether federal law prevents a state-law negligence claim against a company whose role was to arrange transportation rather than operate the truck.

Quick Answer

The Eleventh Circuit ruled in 2024 that the family’s negligent-selection claim against Total Quality Logistics was preempted by the Federal Aviation Administration Authorization Act, often called the FAAAA. However, the legal landscape has since changed. In 2026, the U.S. Supreme Court held that the FAAAA’s safety exception can apply to state-law negligent-hiring claims against freight brokers when the claim concerns the use of motor vehicles in transportation. The availability of a particular claim therefore depends on the facts, jurisdiction, and applicable law.

What Happened in the Fatal Georgia Truck Crash?

According to the lawsuit, a tractor-trailer owned by Florida-based logistics company Hard to Stop was traveling on State Route 73 when the driver attempted an illegal U-turn. The maneuver allegedly caused the truck to block lanes in both directions.

The decedent’s vehicle then collided with the tractor-trailer. He suffered fatal injuries as a result of the crash.

Tractor-Trailer Makes a U-Turn

The truck driver allegedly attempted a U-turn on State Route 73 after missing the entrance to the destination where the load was to be picked up.

Traffic Was Blocked

The tractor-trailer allegedly obstructed multiple lanes, leaving traffic traveling in both directions unable to proceed normally.

A Collision Occurred

The decedent’s vehicle collided with the truck that was blocking the roadway.

The Victim Died

The man died from the injuries he suffered in the crash, prompting his family to pursue a wrongful death lawsuit.

Who Was Named in the Wrongful Death Lawsuit?

The family’s lawsuit named three primary defendants connected to the transportation arrangement and the crash.

The Truck Driver

The driver allegedly made the U-turn that obstructed traffic and led to the fatal collision.

Hard to Stop

The Florida-based logistics company owned the tractor-trailer involved in the crash.

Total Quality Logistics

Total Quality Logistics acted as the freight broker that arranged for Hard to Stop to transport the goods.

Why Was the Freight Broker Sued?

The family’s claims against Total Quality Logistics went beyond simply alleging that the truck driver’s conduct caused the crash. The plaintiffs argued that the broker had a duty to take reasonable steps to ensure that the motor carrier it selected was safe and qualified.

According to the complaint, the plaintiffs alleged that Total Quality Logistics knew or should have known about problems associated with Hard to Stop, including allegations involving driver licensing, vehicle maintenance, and insurance coverage.

The plaintiffs therefore argued that the broker should be held responsible for allegedly failing to investigate the motor carrier before arranging for it to transport the shipment.

The Alleged Duty

The plaintiffs argued that Total Quality Logistics had a duty to exercise reasonable care when selecting the motor carrier responsible for transporting the shipment. In particular, they alleged that the broker should not have selected a carrier with known or discoverable safety concerns.

What Is a Freight Broker?

Freight brokers generally arrange transportation between shippers and motor carriers. They may coordinate the movement of goods without actually owning or operating the truck that transports the shipment.

That distinction became central to this litigation. The question was whether a broker could be sued under state negligence law for allegedly selecting an unsafe motor carrier, or whether federal law prevented the state from imposing that type of requirement on the broker.

Motor Carrier

A motor carrier operates vehicles used to transport property. In a truck accident case, the carrier may be investigated concerning driver qualifications, vehicle maintenance, safety practices, and the conduct of its driver.

Freight Broker

A freight broker generally arranges transportation between a shipper and a motor carrier. The broker may not own the truck or directly employ the driver.

Why the Distinction Matters

A company’s role in a transportation arrangement can affect what legal claims may be available against it. Identifying every company involved in a shipment can therefore be an important part of a truck accident investigation.

The Federal Law at the Center of the Dispute

The dispute centered on the Federal Aviation Administration Authorization Act of 1994, or FAAAA. Although the statute concerns a broad area of transportation regulation, the provision at issue addresses state laws affecting the price, route, or service of motor carriers and brokers involved in the transportation of property.

49 U.S.C. § 14501(c)(1) generally provides that states may not enact or enforce laws having the force and effect of law that relate to a price, route, or service of a motor carrier, motor private carrier, broker, or freight forwarder with respect to transportation of property, subject to statutory exceptions.

The Key Statutory Question

The major issue was whether a state-law claim alleging negligent selection of a motor carrier was preempted by 49 U.S.C. § 14501(c)(1), or whether the statute’s safety exception allowed the claim to proceed.

What Did the Eleventh Circuit Decide?

In July 2024, the U.S. Court of Appeals for the Eleventh Circuit affirmed the dismissal of the family’s negligent-selection claim against Total Quality Logistics. The court relied on its prior decision in Aspen American Insurance Co. v. Landstar Ranger, Inc. and concluded that the FAAAA preempted the claim.

The Eleventh Circuit reasoned that a claim against a broker for allegedly failing to select a safe motor carrier directly concerned the broker’s transportation-arranging services. The court also concluded that the FAAAA’s safety exception did not save the claim because the alleged duty was directed at the broker’s selection service rather than directly at a motor vehicle.

Claim Against the Broker

The family argued that Total Quality Logistics negligently selected or retained an unsafe motor carrier.

FAAAA Preemption

The Eleventh Circuit held that the claim was sufficiently related to the broker’s transportation services to fall within the FAAAA’s preemption provision.

Safety Exception Rejected

At the time, the Eleventh Circuit concluded that the safety exception did not preserve the broker claim under its precedent.

The Law Changed in 2026

The Eleventh Circuit’s 2024 decision is now important historical background rather than the last word on whether federal law preempts negligent-hiring or negligent-selection claims against freight brokers.

In May 2026, the U.S. Supreme Court decided Montgomery v. Caribe Transport II, LLC and held that the FAAAA’s safety exception can encompass state common-law negligent-hiring claims against freight brokers when those claims concern the use of motor vehicles in transportation.

The Supreme Court’s decision rejected the narrower interpretation of the safety exception that had been adopted by some courts and held that the statute’s safety exception applies to this type of motor-vehicle-related negligence claim. The Court therefore changed the national legal landscape surrounding freight-broker liability.

2026 Legal Update

Freight brokers are not automatically immune from negligent-hiring claims. The Supreme Court’s 2026 decision recognized that the FAAAA’s safety exception can preserve a state-law negligent-hiring claim involving a broker’s selection of a motor carrier. Whether a particular lawsuit can proceed still depends on the facts and the applicable state law.

The Supreme Court later denied review in Total Quality Logistics, LLC v. Cox, leaving the Sixth Circuit’s 2025 decision in that separate case in place. Together, the 2026 developments mean that the older Eleventh Circuit analysis should not be presented as the current nationwide rule.

What Is the FAAAA Safety Exception?

The FAAAA contains a safety exception that states that the preemption provision does not restrict a state’s safety regulatory authority with respect to motor vehicles.

The current text of 49 U.S.C. § 14501(c)(2)(A) preserves this state safety authority. In Montgomery, the Supreme Court interpreted that language broadly enough to include a state-law negligent-hiring claim against a broker where the claim concerns the use of motor vehicles in transportation.

What Does “Preemption” Mean?

Federal preemption can prevent state laws or legal claims from operating where Congress has occupied the field or expressly displaced state authority. The FAAAA contains an express preemption provision concerning certain state laws affecting transportation services.

Why Does the Safety Exception Matter?

A claim can fall within the general preemption provision and still survive if a statutory exception applies. The safety exception became the critical issue in the Supreme Court’s 2026 interpretation of the FAAAA.

Does the Supreme Court Decision Guarantee Recovery?

No. The Supreme Court’s interpretation addresses federal preemption. A plaintiff must still establish the elements of an applicable state-law negligence claim and prove the necessary facts.

What Did the Plaintiffs Allege About Hard to Stop?

The plaintiffs alleged that Hard to Stop had a history of safety-related problems that should have caused the broker to investigate the company more closely before selecting it to transport the shipment.

Among the allegations were claims involving the use of improperly licensed drivers, inadequate vehicle maintenance, and insufficient insurance coverage. The plaintiffs argued that these alleged problems should have alerted Total Quality Logistics that Hard to Stop might not be a safe carrier.

Whether those allegations were supported by sufficient evidence was a separate question from whether federal law preempted the claim. That distinction is important in any truck accident lawsuit involving multiple companies.

How Can a Truck Accident Investigation Identify Responsible Parties?

A commercial truck accident can involve several businesses and individuals. The company that owns the tractor-trailer may be different from the company that employs the driver, which may be different from the company that arranged the shipment.

Driver and Motor Carrier Records

Investigators may examine driver qualification files, licensing information, training records, disciplinary history, safety records, and other evidence concerning the driver and motor carrier.

Maintenance and Inspection Records

Maintenance records and inspection documentation can help determine whether mechanical problems or inadequate maintenance contributed to the crash.

Broker and Shipment Records

Contracts, communications, carrier-selection records, safety information reviewed before the shipment, and other broker documents may help determine what the broker knew or should have known about the carrier.

Crash Reconstruction Evidence

Photographs, vehicle data, roadway evidence, witness statements, surveillance footage, and expert accident reconstruction may help establish how the collision occurred.

Why Freight Broker Liability Matters to Truck Accident Victims

A truck accident may involve substantially greater forces and more complicated corporate relationships than an ordinary car accident. Identifying the correct defendants can therefore be a crucial part of pursuing a claim.

When a carrier was selected through a freight broker, the investigation may need to examine not only the driver’s conduct but also the broker’s role in choosing the carrier and the information available at the time of the transportation arrangement.

The Important Takeaway

The question of whether a freight broker can be sued is no longer as simple as saying that federal law automatically protects brokers from negligence claims. The Supreme Court’s 2026 decision makes the FAAAA safety exception an important consideration in cases involving negligent selection of motor carriers.

Can Illinois Truck Accident Victims Sue a Freight Broker?

Illinois truck accident cases can involve the same basic issue discussed in this case: whether a freight broker played a role in selecting a motor carrier whose conduct allegedly caused a crash.

The Supreme Court’s 2026 decision is significant for Illinois because it provides a federal interpretation of the FAAAA safety exception. However, whether a particular Illinois plaintiff has a viable negligent-selection or negligent-hiring claim requires a case-specific analysis of the facts and applicable Illinois law.

Families pursuing wrongful death claims should therefore identify every company and individual involved in arranging, operating, maintaining, loading, or dispatching the commercial vehicle rather than assuming that the truck driver is the only potentially responsible party.

What Damages May Be Available After a Fatal Truck Accident?

When a truck accident results in a death, the surviving family may be entitled to pursue damages under the wrongful death laws applicable to the case. Depending on the circumstances, damages may include losses related to financial support, medical or funeral expenses, and other legally recognized harms.

The specific damages available depend on the governing law, the relationship between the claimant and the deceased, and the evidence establishing the family’s losses.

Financial Losses

A wrongful death claim may address legally recoverable financial losses caused by the death.

Medical and Funeral Costs

Certain accident-related medical or funeral expenses may be recoverable depending on the applicable law.

Losses to Surviving Family

The law may permit recovery for certain losses suffered by surviving family members as a result of the death.

Freight Broker Liability Can Be Fact-Specific

The Georgia case illustrates why trucking litigation can become legally complicated when multiple businesses are involved. The driver, the motor carrier, the owner of the truck, the broker, and other transportation companies may have different roles and different potential defenses.

Federal preemption can also affect which claims are available. As the law continues to develop following the Supreme Court’s 2026 ruling, a careful review of the transportation contracts, carrier-selection process, safety records, and crash evidence can be essential.

Talk to an Urbana, Illinois Truck Accident Attorney

Patel Law, PC represents Illinois residents who have been injured in truck accidents and families pursuing wrongful death claims after fatal commercial-vehicle crashes. Our attorneys can investigate the driver, trucking company, broker, and other parties involved in a collision.

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