Geier v. American Honda Motor Co.
529 U.S. 861 (2000)
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Rule of Law:
A state common-law tort action is impliedly pre-empted if it stands as an obstacle to the accomplishment of the specific methods and objectives of a federal regulatory scheme, even when the governing statute contains a saving clause that preserves common-law claims from express pre-emption.
Facts:
- In 1984, the Department of Transportation (DOT) promulgated Federal Motor Vehicle Safety Standard (FMVSS) 208, which required automobile manufacturers to equip some of their 1987 vehicles with passive restraints.
- The standard was designed to phase in passive restraints gradually and deliberately provided manufacturers with a choice among several options, including airbags, automatic seatbelts, or other technologies, to foster variety and public acceptance.
- American Honda Motor Company, Inc. manufactured a 1987 Honda Accord that was equipped with manual shoulder and lap belts but did not have an airbag or any other passive restraint device.
- American Honda was in full compliance with FMVSS 208 for its 1987 fleet, as the standard only required 10% of its cars to have a passive restraint, a requirement Honda met by installing them in other models.
- In 1992, Alexis Geier was driving her 1987 Honda Accord while wearing her seatbelt.
- Geier collided with a tree and was seriously injured.
Procedural Posture:
- Alexis Geier and her parents sued American Honda in the U.S. District Court for the District of Columbia under state tort law.
- The District Court (trial court) dismissed the lawsuit, holding that the claim was expressly pre-empted by the National Traffic and Motor Vehicle Safety Act.
- Geier, as appellant, appealed the dismissal to the U.S. Court of Appeals for the D.C. Circuit.
- The Court of Appeals affirmed the dismissal, but on the grounds of implied conflict pre-emption, finding that the lawsuit would frustrate the objectives of the federal safety standard.
- The U.S. Supreme Court granted certiorari to resolve a circuit split on the issue.
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Issue:
Does the National Traffic and Motor Vehicle Safety Act of 1966, combined with Federal Motor Vehicle Safety Standard 208, pre-empt a state common-law tort action claiming a manufacturer was negligent for not equipping a 1987 vehicle with an airbag, when the federal standard permitted manufacturers a choice among several different passive restraint systems?
Opinions:
Majority - Justice Breyer
Yes, the state tort action is pre-empted. While the Safety Act's saving clause prevents the express pre-emption of common-law tort actions, it does not bar the ordinary operation of implied conflict pre-emption principles. The tort claim in this case actually conflicts with the objectives of FMVSS 208 because it would effectively require manufacturers to install airbags, thereby frustrating the specific federal regulatory objective of providing manufacturers with a choice among various passive restraint systems to promote variety, technological development, and gradual public acceptance. A state rule of law that removes the choice and variety deliberately sought by the federal standard stands as an obstacle to the accomplishment of the regulation's purposes and is therefore pre-empted.
Dissenting - Justice Stevens
No, the state tort action is not pre-empted. The Safety Act's saving clause unambiguously preserves common-law liability, and federal safety standards are intended to be minimums, not ceilings. A tort action that encourages manufacturers to adopt safety features beyond the federal minimum does not frustrate the Act's primary purpose of reducing injuries; it furthers it. The majority's reliance on regulatory commentary and history to find a conflict with the secondary goals of 'gradualism' and 'variety' is an unprecedented extension of pre-emption doctrine that improperly reads the saving clause out of the statute and disrespects the traditional police powers of the states.
Analysis:
This case significantly clarifies the relationship between statutory saving clauses and the doctrine of implied conflict pre-emption. It establishes that a saving clause, while preserving common-law claims from express pre-emption, does not immunize them from being pre-empted if they conflict with federal regulatory objectives. The ruling expands the scope of 'obstacle pre-emption' by holding that a conflict can exist not only with a regulation's ultimate goal (e.g., safety) but also with the specific means or methods chosen by an agency to achieve that goal (e.g., providing a choice of technologies). This gives federal agencies substantial power to displace state tort law through detailed regulatory schemes, even without an explicit statement of pre-emptive intent.
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