The Supreme Court recently decided that Federal Motor Vehicle Safety Standard 208 (FMVSS 208), which requires auto manufacturers to install lap-and-shoulder seatbelts on seats next to a vehicle’s door frames, but allows manufacturers to choose between simple lap belts or lap-and-shoulder belts for rear inner seats (such as middle seats or those next to a minivan’s aisle), did not pre-empt a state tort suit that would deny manufacturers a choice of belts for rear inner seats by imposing tort liability on those who choose to install a simple lap belt. Williamson v. Mazda Motor of America, Inc., No. 08-1314 (Feb. 23, 2011) .pdf.
In 2002 the Williamson family’s Mazda minivan was struck head-on by another vehicle. One family member sitting in a rear aisle seat, wearing a lap belt, died in the accident. Two other family members wearing lap-and-shoulder belts survived. They sued Mazda saying it should have installed lap-and-shoulder belts on rear aisle seats. The California trial court dismissed the claim and the California Court of Appeal affirmed, relying on an earlier Supreme Court case, Geier v. American Honda Motor Co., 529 U.S. 861 (2000), where the court held that a different portion of FMVSS 208 requiring installation of passive restraint devices (airbags) pre-empted a state tort suit that sought to hold an auto manufacturer liable for failure to install a particular kind of passive restraint. The Williamsons sought certiorari, and the Supreme Court granted review because other courts have interpreted Geier as indicating that FMVSS 208 pre-empts state tort suits similar to the Williamsons’. Holding that FMVSS 208 does not pre-empt these suits, the Supreme Court reversed the California Court of Appeal’s decision.
The court explained that a state law that “stands as an obstacle to the accomplishment and execution of the full purposes and objectives of a federal law” is preempted, and in Geier it determined – based on the airbag regulation’s history, the promulgating agency’s explanation of its objectives, and the agency’s views of the regulation’s pre-emptive effect – that giving auto manufacturers a choice among different kinds of passive restraint devices was a significant objective of the airbag regulation, and the tort suit stood as an obstacle to the accomplishment of that objective. But the court determined, based likewise on history and agency interpretation – that choice was not a significant regulatory objective of the seatbelt regulation in Williamson, so even though the state tort suit might restrict the manufacturer’s choice, it did not stand as an obstacle to the regulation’s full purposes and objectives, and was therefore not pre-empted.