Williamson v. Mazda Motor of America, Inc.
179 L. Ed. 2d 75
| SCOTUS | 2011Background
- FMVSS 208 (1989 version) permits rear inner seats to use either lap belts or lap-and-shoulder belts, not mandating a single type.
- In 2002, Thanh Williamson died in a Mazda minivan crash while wearing a lap belt; Delbert and Alexa Williamson survived with lap-and-shoulder belts.
- Williamsons filed a California tort suit against Mazda alleging failure to install lap-and-shoulder belts on rear inner seats.
- California courts dismissed the suit based on pleadings and existing case law, citing Geier v. American Honda as precedent for pre-emption analysis.
- Geier held that federal regulation preserving manufacturer choice can pre-empt a tort claim premised on eliminating that choice; this case centers on a similar issue for seatbelt types.
- The Supreme Court reversed, holding FMVSS 208 does not pre-empt the Williamsons’ state tort action because the regulation’s history and objectives do not show a significant objective of preserving such a choice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does FMVSS 208 pre-empt a state tort claim? | Williamsons contend the suit blocks the choice Congress granted. | Mazda argues the suit conflicts with federal objective to limit liability while preserving choice. | No pre-emption; no obstacle to federal objectives. |
| Do express pre-emption and saving clauses resolve the issue? | Saving clause preserves common-law actions; express pre-emption does not bar tort claims here. | Statutory text pre-emption could bar conflicting state actions. | Saving clause does not foreclose ordinary conflict pre-emption; neither clause pre-empts here. |
| Is there conflict pre-emption under ordinary principles? | Tort claim enforces a stricter standard not required by federal regulation. | Regulation’s objective to maintain choice could be obstructed by the suit. | Regulation does not present an obstacle to full federal objectives; not pre-empted. |
| Did the agency’s objectives in Geier justify pre-emption here? | The Geier framework should apply, showing a significant regulatory objective that requires choice. | This case differs; DOT did not deem rear-seat belt choice a significant objective here. | Distinguishes Geier; no implied pre-emption; trial court reversal affirmed. |
Key Cases Cited
- Geier v. American Honda Motor Co., 529 U. S. 861 (U.S. 2000) (saving clause does not bar ordinary conflict pre-emption; choice may or may not be a significant objective)
- Hines v. Davidowitz, 312 U. S. 52 (U.S. 1941) (obstacle pre-emption standard)
- Cipollone v. Liggett Group, Inc., 505 U. S. 504 (U.S. 1992) (conflict pre-emption can pre-empt state law where conflict with federal statute/regulation)
- Medtronic, Inc. v. Lohr, 518 U. S. 470 (U.S. 1996) (concepts of saving clause and scope of express pre-emption)
- Hillsborough County v. Automated Medical Laboratories, Inc., 471 U. S. 707 (U.S. 1985) (state laws can be pre-empted by federal regulations)