Defective products defense attorneys may have one less weapon in their arsenal to combat products liability litigation after last week’s United Statements Supreme Court decision in Williamson v. Mazda Motor of America (No. 08-1314).
On February 23, 2010, the USSC reversed a California decision that found in favor of Mazda’s preemption defense against a state tort lawsuit regarding a products liability claim. The plaintiffs, the Williamson family and Thanh Williamson’s estate, brought a products liability lawsuit after Thanh Williamson died in a car accident because the rear aisle seat of the Mazda minivan in which she was sitting had only a lap seat belt, rather than the more customary lap-and-shoulder belt. The California trial court dismissed the Williamson’s claim on the pleadings, holding that federal vehicle safety regulations conflicted with their state tort claim, and therefore preempted it. The California Court of Appeal affirmed the decision, despite the Williamson’s contention that their state claim not only does not conflict with federal regulations, but that it furthers federal objections of car safety.
Manufacturer liability will certainly be affected by the USSC’s decision to curb the extention of preempting state-law claims in favor of minimum standards set by federal regulations. The California Court of Appeals relied heavily on a 2000 decision involving implied preemption, Geier v. American Honda Motor Co. In Geier, the USSC found that the 1984 version of Federal Motor Vehicle Safety Standard (FMVSS) 208 preempted a state tort suit against a car manufacturer on a failure to install airbags. However, in Williamson, the USSC held that the most current version of FMVSS, which requires the installation of lap-and-shoulder belts on all seats positioned next to doors or frames, but allows manufacturers to decide for themselves whether to install those belts or only lap belts on rear aisle seats, does not preempt state common-law tort claims resulting from the failure to install lap-and-shoulder seatbelts.
- For a legal tune up on the Supremacy Clause and preemption principles, see Hines v. Davidowitz, 312 U.S. 52, 67 (explaing that "under ordinary conflict pre-emption principles, a state law that stands as an obstacle to the accomplishment of a federal law is preempted).
In Geier, the contested state law did "stand as an obstacle to the accomplishment" of an airbag federal regulatory objective: to provide manufacturers the choice among several kinds of passive restraint systems. Surveying the regulation’s history, the USSC found that the Department of Transportation (DOT) had a long-standing objective to give car manufacturers their freedom of choice in terms of airbag installment.
However, the USSC made it clear last week that airbag installation and seatbelt design choice are mutually exclusive. The USSC unanimously held that Geier‘s implied preemption argument was inapplicable to the instant case because car manufacturers’ seatbelt-design choice "was not, in and of itself, a significant objection of the federal regulation in question," as it was for airbag federal regulations at issue in Geier, says James Black of SCOTUSblog. Unlike the choice between installing active passenger restraints (seatbelts) versus passive seat restraints (airbags) discussed in Geier, FMVSS 208’s decision "not to mandate a more elaborate restraint system was motivated primarily by cost, and . . . an agency’s cost-effectiveness judgment was not, by itself, preemptive, since the statute specified that the agency could only enact minimum standards," explains Black in his analysis of the Williamson opinion.
The Court concluded its opinon that state tort lawsuits "may restrict the manufacturer’s choice" but any such resstriction "did not rise to the level of a preemptive ‘obstacle to the accomplishment of" FMVSS’s national objectives.
The Williamson decision will hopefully preserve the once-threatened legal platform in state court for future victims of car accidents to seek the justice they deserve for manufacturers’ "choices" in seatbelt design.