Memorandum · standard of care

After the Montgomery ruling, "we ran a check" is no longer a defense.

To
Legal, Risk & Underwriting
Re
Carrier-selection exposure
Prepared by
GroundCheck
Classification
Shareable · internal

A litigation-aware read of where carrier-selection liability now sits — and the specific record a broker or insurer needs to answer for a decision after the fact.

01
What changed

Negligent-selection theory is not new. What changed is federal preemption. On May 14, 2026, a unanimous Supreme Court held in Montgomery v. Caribe Transport II, LLC that a broker's duty to use reasonable care in selecting a carrier falls within the FAAAA's safety exception — so the preemption defense brokers relied on for more than a decade no longer applies in any state. A broker who tenders freight to an unfit carrier can now be treated as a proximate cause of what follows, in front of a jury, in all fifty states.

The practical shift is evidentiary. It is no longer enough to have had a process. The question in the room is whether you can produce the decision: what you knew at the moment of tender, what the signals were, who weighed them, and what they concluded. An unproduceable process reads, to a jury, as no process at all.

The operative question
"Show the court the decision — not the dashboard you had access to."
02
The new standard of care

A defensible selection today rests on four load-bearing elements. Miss any one and the record has a hole a plaintiff's expert will find. Together they describe a reasonable process — carried out by a named person, at the moment of tender, and maintained afterward.

  1. 01
    Identity verified
    The carrier is who it claims to be — not a reincarnation of a revoked authority operating under a fresh MC.
  2. 02
    Risk assessed
    Authority, insurance and safety signals were weighed on the record — with the reasoning behind the conclusion preserved, not just the conclusion.
  3. 03
    Decision documented
    A named reviewer reached a decision at a fixed time — including any override of a flag — and that record is tamper-evident.
  4. 04
    Monitoring maintained
    Material changes after tender were tracked and appended — the file was current, not frozen at onboarding.
03 — Argument, paired with evidence

Each element maps to a piece of the record.

The legal argument is only as good as the artifact behind it. For each element of the standard, this is the concrete evidence GroundCheck produces.

Element 01 · Identity verified
Reincarnation caught, on the record.

The phoenix pattern — a revoked authority reappearing under a new MC — is named, evidenced by the shared identifiers that triggered it, and attached to the file.

Pattern · reincarnated carrier3 identifiers
Registered address = MC-04 (revoked 2024)
Officer of record = MC-04
Phone reused across 3 authorities
Element 02 · Risk assessed
A score that shows its reasoning.

Every point is traceable to a factor and its evidence. The conclusion and the reasoning are both preserved — so the assessment survives cross-examination.

Confidence · MC-1148Reasoned
61
Watch
Address reuse pattern−14
Authority age < 90 days−5
Elements 03 & 04 · Documented & monitored
A named decision, sealed and kept current.

Who decided, when, and on what basis — including the override — under a cryptographic seal. Material changes after tender append to the same file.

Selection recordProceed · sealed
DecisionPROCEED (override)
Decided byJ. Okafor · 14:03:41Z
Chain IDa91f·7c2e
SEALED SHA256 a91f·7c2e·bb04·9d1a
04 — The exhibit

What gets produced when the decision is questioned.

One record, redacted for filing, that answers every element of the standard in the order a court asks for them.

Selection record — Exhibit A REDACTED FOR FILING
Identity & authority
Carrier · LLC
MC-1148 / DOT 39
Authority: active
Insurance: $1M active
Signals at tender
Address reuse
Phone reuse
Insurance verified
Decision & seal
Decision: PROCEED
By: J. Okafor
14:03:41Z
Chain: a91f·7c2e
SEALED SHA256 a91f·7c2e·bb04·9d1a — TAMPER-EVIDENT · monitoring appended through claim date

Bring the standard-of-care layer to your desk.

Before the next tender — and before the next claim. Share this brief with your legal and underwriting teams, or discuss your exposure with ours.

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