Priester v. Cromer
401 S.C. 38
| S.C. | 2012Background
- Priester v. Cromer comes on remand after USSC Williamson; issues preemption under FMVSS 205.
- Appellant claims 1997 Ford F-150 glazing was defective; laminated glass would have reduced ejection.
- Ford moved for summary judgment; trial court held FMVSS 205 preempted state-law claims.
- USSC Williamson clarified that manufacturer choice alone does not imply preemption absent a significant federal objective.
- Priester court reaffirms preemption under Williamson, examining FMVSS 205 text, history, and NHTSA's wants to promote safety.
- Court concludes laminated-glass claims would obstruct FMVSS 205’s safety objectives and are preempted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Williamson-based preemption applies to laminated-glass claims | Priester: preemption because choice obstructs federal objective | Ford: choice alone may preempt under Williamson framework | Preemption upheld; claims obstruct significant federal objective |
| Is FMVSS 205 a minimum safety standard or a regime permitting meaningful choice | Laminate vs tempered glass as minimum standard may allow tort claims | FMVSS 205 preserves option; preemption possible if objective protected by choice | FMVSS 205 supports preemption when choice obstructs safety objectives |
| Did agency history show a significant objective in preserving manufacturer choice | Agency intended mix of devices to enhance safety | Agency decisions not shown as significant objective justifying preemption | Agency history insufficient to negate preemption; claims preempted |
| Are the preemption questions controlled by Geier as refined in Williamson | Geier framework supports preemption due to variety integral to safety | Williamson limits Geier, requiring explicit significant objective | Geier/Williamson applied; laminated-glass claims preempted |
Key Cases Cited
- Geier v. American Honda Motor Co., 529 U.S. 861 (2000) (implied preemption when variety furthers federal objectives)
- Williamson v. Mazda Motor of America, Inc., 131 S. Ct. 1131 (2011) (manufacturer choice alone not enough; must further significant objective)
- Sprietsma v. Mercury Marine, 537 U.S. 51 (2002) (distinguishes preemption in absence of express regulation)
- O’Hara v. General Motors Corp., 508 F.3d 753 (5th Cir. 2007) (characterizes FMVSS 205 as minimum standard in some analyses)
- Hinton v. MCI Sales & Service, Inc., 329 S.W.3d 475 (Tex. 2010) (Texas rule on preemption under FMVSS 205 framed by Williamson)