Supreme Court allows state law claim to proceed.
In its 8-0 decision in Williamson v Mazda Motor of America, Inc. earlier this year, the U.S. Supreme Court held that the Department of Transportation (DOT)’s Federal Motor Vehicle Safety Standard 208 (FMVSS 208) does not pre-empt a state tort lawsuit claiming an auto manufacturer negligently chose to install lap-only seatbelts in the rear seat instead of lap-and-shoulder belts, a choice allowed under the federal standard.
The Supreme Court had previously held that a state negligence claim is pre-empted only when the claim would impede the achievement of a “significant” purpose of the federal regulation. In a 2000 decision, the Court reviewed a state claim that a manufacturer had negligently installed driver-side automatic seatbelts instead of airbags. The Supreme Court, in Geier v American Honda Motor Co., found the state claim preempted because the DOT had purposely given manufacturers a choice to install airbags or automatic seatbelts due to safety-related concerns about consumers’ acceptance of new restraint technology.
Writing for the Court majority in both Geier and Williamson, Justice Stephen Breyer distinguished the two cases. In the Williamson case, Breyer emphasized that the DOT had allowed manufacturers to choose between seatbelt types for rear inner seats for cost and design reasons, not consumer acceptance concerns. The choice the DOT afforded manufacturers, in other words, did not serve a significant regulatory objective, so state claims could go forward in Williamson even though they were preempted in Geier.
Justice Sotomayor and Justice Thomas filed concurring opinions, while Justice Kagan did not participate in the Williamson decision.