MCI Sales and Service, Inc. v. Hinton
329 S.W.3d 475
| Tex. | 2010Background
- Bus crash involving Central Texas Trails and a motorcoach; lack of passenger seatbelts and glazing choices were alleged defects.
- Motorcoach manufactured by MCI; federal FMVSS 208 governed driver seatbelts only and later developments discussed, without a passenger-seatbelt requirement at the time of manufacture.
- FMVSS 205 allowed a choice of glazing materials (laminated or tempered glass); MCI complied with FMVSS 205.
- Bankruptcy plan apportioned a liability fund among claimants via Apportionment Plan or Litigation Plan; Central Texas deposited $5 million and agreed to ongoing payments.
- Plaintiffs pursued claims in state court against MCI; jury found design defects related to seatbelts and glazing; subsequent bankruptcy proceedings affected liability apportionment.
- Court addressed federal preemption of state-law tort claims under the Safety Act and Texas Chapter 33 settling-party issues, then remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Preemption of seatbelt claim by federal law | Geier framework favors preemption. | No express preemption; regulatory silence insufficient. | Seatbelt claim not preempted by federal law. |
| Preemption of glazing-materials claim by federal law | FMVSS 205 creates a conflict with state tort rule. | FMVSS 205 leaves a minimum standard allowing state refinements. | Glazing claim not preempted; FMVSS 205 is a minimum standard. |
| Whether Central Texas is a settling person under Chapter 33 | Central Texas's payments/compromise constitute a settling. | No valid settlement at time of submission; not a settling person. | Court held Central Texas a settling person; remanded for proportionate liability question. |
Key Cases Cited
- Geier v. American Honda Motor Co., 529 U.S. 861 (U.S. 2000) (FMVSS 208 choice rationale; saving clause interpretation; obstacle preemption)
- Sprietsma v. Mercury Marine, 537 U.S. 51 (U.S. 2002) (Regulatory non-action preemption not express; need explicit policy intent)
- Myrick v. Freightliner Corp., 514 U.S. 280 (U.S. 1995) (Absence of federal standard cannot implicitly extinguish state law)
- O'Hara v. General Motors Corp., 508 F.3d 753 (5th Cir. 2007) (FMVSS 205 as minimum standard; glazing materials not preempted)
- Morgan v. Ford Motor Co., 224 W.Va. 62, 680 S.E.2d 77 (W.Va. 2009) (Court held FMVSS 205 preemption analysis different; not controlling here)
- Gilcrease v. Garlock, Inc., 211 S.W.3d 448 (Tex. App.-El Paso 2006) (Settling-claims interpretation; unconditional promises considered settlements under 33.011)
- Cimino v. Raymark Indus., Inc., 751 F. Supp. 649 (N.D. Tex. 1990) (Bankruptcy-related payment promises; contingent settlements)