Background
Willy Hodge, his wife, and their three children were injured when a semitruck owned and operated by Touba Transportation struck their vehicle. Touba was hired by Coyote Logistics, which was hired by Schneider Logistics, which was in turn hired by Molson Coors Beverage Company. The Hodges sued Coyote and Molson Coors, alleging negligent hiring. The district court granted judgment on the pleadings, ruling that the Federal Aviation Administration Authorization Act preempted the claim against Coyote and that Molson Coors could not be liable for a carrier it did not directly hire.
The court’s reasoning
The court reviewed the claim against Coyote Logistics de novo. It noted that prior Eleventh Circuit precedent held that the Federal Aviation Administration Authorization Act preempted negligent hiring claims against brokers, but that precedent was abrogated by the Supreme Court’s decision in Montgomery v. Caribe Transportation. Because the district court relied on this abrogated law, the court vacated the judgment on that claim and remanded for further proceedings. Regarding the claim against Molson Coors, the court applied Maryland law, which requires a plaintiff to show that the employer failed to conduct a reasonable inquiry and that the hiring was a proximate cause of the injury. The court found that Molson Coors hired Schneider, who hired Coyote, who hired Touba. The plaintiffs failed to provide authority extending negligent hiring liability to a party three steps removed from the actual hiring or to show that Molson Coors’ influence in the process constituted actual hiring. Thus, the claim against Molson Coors was properly dismissed.
What it means going forward
The decision allows negligent hiring claims against logistics brokers to proceed in the Eleventh Circuit following the Supreme Court’s ruling in Montgomery, while maintaining that liability for negligent hiring does not extend to companies that do not directly hire the carrier in question.