Negligence-Motor Vehicle-State’s Regulatory Authority

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7^th Circuit Court of Appeals

Case Name: Ying Ye v. GlobalTranz Enterprises, Inc.

Case No.: 22-1805

Officials: Brennan, Scudder, and St. Eve, Circuit Judges.

Focus: Negligence-Motor Vehicle-State’s Regulatory Authority

Ye pursued a case against GlobalTranz, a freight broker, after her husband’s death in a highway accident. According to Illinois law, she argued that GlobalTranz was negligent in hiring the motor carrier (Sunrise), which employed the truck driver responsible for the accident. Ye obtained a default judgment of $10 million against Sunrise.

The district court ruled that Ye’s claim against GlobalTranz was barred by the express preemption provision of the Federal Aviation Administration Authorization Act in 49 U.S.C. 14501(c)(1). The court also determined that the Act’s safety exception in 14501(c)(2)(A) did not apply to save the claim. The Seventh Circuit upheld this decision and pointed out the potential adverse economic impact of imposing state negligence standards on brokers. Congress had broadly disallowed state laws that hinder its deregulatory objectives, while including a specific exemption for laws pertaining to a state’s “safety regulatory authority.”

Ye’s negligent hiring claim against GlobalTranz falls under the express prohibition in 14501(c)(1) concerning the enforcement of state laws related to a broker’s service concerning the transportation of property. The court rejected the “safety exception” argument, stating that a common law negligence claim enforced against a broker does not pertain to motor vehicles.

Affirmed.

Decided 07/18/23

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