February 24, 2011

Supreme Court Decides Williamson v. Mazda Motor of America, Inc

On February 23, 2011, the Supreme Court decided Williamson v. Mazda Motor of America, Inc, No. 08-1314, holding that the 1989 version of the Federal Motor Vehicle Safety Standard 208 ("FMVSS 208"), which allows auto manufacturers to choose whether to install simple lap belts or lap-and-shoulder belts on rear inner and aisle seats (i.e. seats situated along the center axis of the vehicle), does not preempt state tort actions seeking to impose liability on manufacturers who choose to install simple lap belts.

Thanh Williamson was killed when her family's Mazda minivan was struck by another vehicle.  She was sitting in a rear aisle seat and was wearing a simple lap belt.  Delbert and Alexa Williamson wore lap-and-shoulder belts and survived the accident. 

Delbert and Alexa, along with Thanh's estate, filed a tort action in California state court, claiming that Mazda should have installed lap-and-shoulder belts on rear aisle seats instead of simple lap belts.  The state trial court dismissed the action on the ground that it was preempted under FMVSS 208.  The California Court of Appeals affirmed, holding that the case was governed by Geier v. American Honda Motor Co., 529 U.S. 861 (2000), which held that the 1984 version of FMVSS 208 preempted state tort actions that, if successful, would deprive auto manufacturers of the choice about whether to install airbags or other passive restraint systems.  The appeals court explained that Williamson's tort suit, if successful, would similarly deprive auto manufacturers of the choice about whether to install simple lap belts or lap-and-shoulder belts in rear inner and aisle seats. 

The Supreme Court reversed.  The Court explained that Geier held that state tort actions were  preempted in that case because requiring airbags would have undermined an important regulatory objective—namely, giving "auto manufacturers a choice among different kinds of passive-restraint devices."  The Department of Transportation ("DOT") promulgated the 1984 regulation hoping that by giving auto manufacturers a choice of passive restraints, it could (1) avoid public backlash against airbags, and (2) give manufacturers time to improve airbag safety.  Choice, however, was not an important objective of the 1989 regulation.  Unlike the earlier regulation, DOT was not concerned about consumer acceptance or issues of safety, but instead worried about cost effectiveness.  But the Court held that mere concern about cost effectiveness does not show preemptive intent.  The Court also found persuasive the Solicitor General's opinion that FMVSS 208 does not preempt Williamson's tort suit.    

Justice Breyer delivered the opinion of the Court, in which Chief Justice Roberts and Justices Scalia, Kennedy, Ginsburg, Alito, and Sotomayor joined.  Justice Sotomayor filed a concurring opinion.  Justice Thomas filed an opinion concurring in judgment.  Justice Kagan took no part in the decision of the case.

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