Supreme Court finds No Preemption in Lap Belt Only Case: Protects Family

Williamson v. Mazda


The Supreme Court in a unanimous judgment will let Mazda be sued in California courts in a case involving a woman who died while wearing a seat belt across her lap in her family's minivan.
The high court in a unanimous judgment agreed to let the lawsuit go forward, despite complaints from the car company that federal regulators gave it an option on whether to install lap belts or lap-and-shoulder belts in the middle seats in the back of the van.
Justice Stephen Breyer, who wrote the majority judgment, said the only way that Mazda would be immune is if the "significant objective" of the federal regulation was to give auto manufacturers a choice of which seat belts to install.
The Transportation Department "gave no indication that its safety goals required the mixture of seatbelt types that resulted from manufacturers' ability to choose different options," said Justice Sonia Sotomayor in a concurring judgment.
Added Breyer: The more important reason why DOT did not require lap-and-shoulder belts for rear inner seats was that it thought that this requirement would not be cost-effective. The agency explained that it would be significantly more expensive for manufacturers to install lap-and shoulder belts in rear middle and aisle seats than in seats next to the car doors. But that fact - the fact that DOT made a negative judgment about cost effectiveness - cannot by itself show that DOT sought to forbid common law tort suits in which a judge or jury might reach a different conclusion."
Justice Bryer sited Geier often, pulling it back into the preemption argument.
"In Geier, then, the regulation's history, the agency explanation, and its consistently held interpretive views indicated that the regulation sought to maintain manufacturer choice in order to further significant regulatory objectives. Here, these same considerations indicate the contrary. We consequently conclude that, even though the state tort suit may restrict the manufacturer's choice, it does not "stan[d] as an obstacle to the accomplishment . . . of the full purposes and objectives" of federal law."

The case is Williamson v. Mazda, 08-1314. Click here for the Opinion: 08-1314_Opinion_(02-23-11).pdf