On May 27, 2026, the U.S. District Court for the Central District of California granted summary judgment in favor of Husch Blackwell client, Continuum Transportation Services Ltd. (Continuum).

The decision, a significant win for Continuum, further clarifies the standing requirements for Carmack Amendment claims in the Ninth Circuit—that a transportation broker generally cannot bring a claim under the Carmack Amendment against a motor carrier unless it constitutes a “person entitled to recover under the receipt or bill of lading” within the meaning of 49 U.S.C. § 14706(a)(1), or otherwise obtains an assignment or right in subrogation.

The genesis of the case was a dispute beginning in 2023 when Raymen Investments (Rayem) retained Quaker Transportation (Quaker) to transport a shipment of yarn and Quaker, acting as a broker, hired Continuum to handle the actual shipping. When a truck carrying the load of yarn rolled over, causing damage to the goods and resulting in financial losses, Rayem filed suit against Quaker asserting claims for breach of contract and negligence. Quaker, in turn, filed a third-party complaint against Continuum, asserting a single cause of action under the Carmack Amendment, 49 U.S.C. § 14706, and sought to hold Continuum liable for any damages Quaker may potentially owe to Rayem.

In granting Continuum’s motion for summary judgement, the district court rejected Quaker’s effort to impose liability on Continuum under the Carmack Amendment based on Quaker’s mere potential for liability to Rayem, holding that Quaker failed to establish standing as a matter of law. Specifically, the court found that Quaker, acting as a broker, did not demonstrate that it was a “person entitled to recover under the receipt or bill of lading” under which it was entitled to recover.

For details on the decision—and what it means for motor carriers, freight brokers, shippers, and logistics companies navigating cargo loss disputes in the Ninth Circuit—we encourage you to read the full legal update.