The U.S. Supreme Court has ruled that federal motor vehicle safety standards giving manufacturers a choice as to the type of seat belt to install for the use of rear-seat passengers do not preempt state-law claims that, if successful, would deny manufacturers that choice and impose an obligation to install one type of seat belt only.Williamson v. Mazda Motor of Am., Inc., No. 08-1314 (U.S., decided February 23, 2011). According to the Court, “providing manufacturers with this seatbelt choice is not a significant objective of the federal regulation. Consequently, the regulation does not pre-empt the state tort suit.”
The case involved a minivan accident in which a rear-seat passenger, who had a lap-only seatbelt to use, died. Litigation alleging that a combination lap-and-shoulder restraint would have prevented the death was dismissed as preempted by the California state courts considering the matter. More information about the case appears in the May 27, 2010, Issue of this Report.
According to Justice Stephen Breyer, writing for the Court, while the federal law’s express preemption clause cannot preempt a common-law tort action because the law also has a savings clause for tort lawsuits, the savings clause cannot “foreclose or limit the operation of ordinary conflict pre-emption principles.” Thus, the issue before the Court was “whether, in fact, the state tort action conflicts with the federal regulation.”
Examining the regulation’s history, the agency’s contemporaneous explanation and its consistently held interpretative views about the choice given to manufacturers, the court concluded, “even though the state tort suit may restrict the manufacturer’s choice, it does not ‘stan[d] as an obstacle to the accomplishment … of the full purposes and objectives’ of the federal law.” The Court reversed the California Court of Appeal’s judgment, and the claims will be allowed to proceed.