Reported / Citable
Background
Kyle Haney alleged that Mamadiyor Ismatov, while driving a tractor-trailer on Interstate 10 in Orange County, Texas, struck Haney’s vehicle on January 26, 2025. Haney alleged that the impact forced his vehicle into a concrete barrier and that the tractor-trailer caught fire, causing him personal injuries and damages.
According to the amended complaint, Ismatov was hauling Amazon cargo in an Amazon-owned trailer from Pennsylvania to an Amazon fulfillment center in Houston. Haney alleged that Ismatov was acting for ORM Logistics, Lleetta Trucking, and/or the Amazon defendants. He asserted respondeat superior, negligent hiring, training, and supervision, and negligent entrustment claims against Amazon. Amazon moved to dismiss under Rule 12(b)(6), arguing that the Federal Aviation Administration Authorization Act preempted the claims and that the allegations were insufficiently pleaded.
The Court’s Holding
Judge Marcia A. Crone denied Amazon’s motion to dismiss. The court held that the FAAAA’s express-preemption provision applied even though Haney characterized Amazon as a shipper, because the claims against Amazon were connected to carriers’ rates, routes, or services.
But the court held that each challenged claim fell within the FAAAA’s motor-vehicle-safety exception. Relying on the Supreme Court’s decision in Montgomery v. Caribe Transportation II, LLC, the court concluded that Haney’s negligent hiring, training, and supervision allegations concerned the safe selection and oversight of the driver and carriers. The respondeat superior claim likewise concerned the collision involving a motor vehicle, and the negligent-entrustment claim concerned Amazon’s alleged entrustment of its trailer to an allegedly incompetent driver. The court also held that the amended complaint plausibly alleged the employment or agency relationship, Amazon’s alleged duty and breach, and the elements of negligent entrustment.
Key Takeaways
- FAAAA preemption may apply to claims against a shipper when those claims are connected to motor-carrier services.
- Texas tort claims concerning the safe hiring, training, supervision, or entrustment of trucking personnel and equipment can fall within the FAAAA safety exception.
- At the pleading stage, allegations that Amazon controlled or employed the driver and carriers, coupled with allegations connecting that relationship to the crash, were sufficient to proceed.
Why It Matters
The ruling permits discovery on whether Amazon had the alleged employment, agency, control, and safety-related responsibilities for the driver, carriers, and trailer. It also applies Montgomery beyond a broker negligent-hiring claim to related trucking-crash theories against an alleged shipper.