Wyoming District Court Holds that Vicarious Liability, Negligent Hiring/Selection, and Joint Enterprise Claims Against C.H. Robinson are Preempted by the FAAAA and Not Saved by the “Safety Exception”

On June 24, 2025, the United States District Court for Wyoming held that plaintiff’s claims for vicarious liability, negligent hiring/selection, and joint enterprise against C.H. Robinson were: 1) preempted by the Federal Aviation Administration Authorization Act of 1994 (“FAAAA”) found in 49 U.S.C. § 14501(c)(1), and 2) not saved by the “safety exception” found in 49 U.S.C. § 14501(c)(2)(A). See Wyatt v. CTS Transit, Inc., No. 23-CV-219-SWS, ECF No. 181 (D. Wyo. June 24, 2025). 

In Wyatt, the freight broker, C.H. Robinson Worldwide, Inc. (“C.H. Robinson”), contracted with a motor carrier to transport a load. An accident occurred and plaintiff filed a personal injury lawsuit against numerous defendants, including C.H. Robinson, claiming it was vicariously liable for the negligence of the motor carrier and driver, that it negligently hired/selected the motor carrier, and that it was in a joint venture with the motor carrier.

Though the district court initially denied C.H. Robinson’s motion to dismiss, it subsequently granted C.H. Robinson summary judgment, finding that all of plaintiff’s claims were preempted by the FAAAA and not saved by the “safety exception.” In reaching this decision, the district court primarily relied upon Ye v. GlobalTranz Enterprises, Inc., 74 F.4th 453 (7th Cir. 2023) and Aspen Am. Ins. Co. v. Landstar Ranger, Inc., 65 F.4th 1261 (11th Cir. 2023), while expressly rejecting Miller v. C.H. Robinson Worldwide, Inc., 976 F.3d 1016 (9th Cir. 2020).

We continue to recommend that freight brokers assert the FAAAA preemption defense early, file dispositive motions, and consider filing appeals where appropriate so that other state and federal appellate courts decide this issue, and the Supreme Court of the United States may be inclined to accept a writ of certiorari.