Williamson v. Mazda Motor of America, Inc.
562 U.S. 323, 179 L. Ed. 2d 75, 2011 U.S. LEXIS 1711 (2011)
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Rule of Law:
Federal Motor Vehicle Safety Standard 208, which provides manufacturers a choice in installing simple lap belts or lap-and-shoulder belts in rear inner seats, does not preempt a state tort suit alleging failure to install lap-and-shoulder belts, because manufacturer choice in this specific context is not a "significant regulatory objective" of the federal regulation.
Facts:
- Federal Motor Vehicle Safety Standard 208 (1989 version) requires auto manufacturers to install seatbelts on rear seats of passenger vehicles.
- FMVSS 208 mandates lap-and-shoulder belts on rear outer seats (next to vehicle doors or frames).
- For rear inner seats (middle seats or those next to a minivan’s aisle), FMVSS 208 provides manufacturers a choice to install either simple lap belts or lap-and-shoulder belts.
- In 2002, the Williamson family was involved in a head-on collision while riding in their 1993 Mazda minivan.
- Thanh Williamson was sitting in a rear aisle seat, wearing a simple lap belt that Mazda had installed in that position.
- Thanh Williamson died in the accident.
- Delbert and Alexa Williamson, who were wearing lap-and-shoulder belts, survived the accident.
Procedural Posture:
- Thanh Williamson's estate, Delbert Williamson, and Alexa Williamson (the Williamsons) brought a tort suit against Mazda Motor of America, Inc. (Mazda) in a California trial court.
- The California trial court dismissed the tort claim based on the pleadings, ruling that the claim was preempted by federal law.
- The California Court of Appeal affirmed the dismissal, holding that the federal regulation, Federal Motor Vehicle Safety Standard 208, preempted the state tort suit, drawing parallels to Geier v. American Honda Motor Co.
- The Williamsons, as petitioners, sought certiorari from the Supreme Court of the United States.
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Issue:
Does Federal Motor Vehicle Safety Standard 208 (1989 version), which gives automobile manufacturers a choice between installing lap belts or lap-and-shoulder belts in rear inner seats, preempt a state tort suit alleging negligence for choosing to install a simple lap belt?
Opinions:
Majority - Justice Breyer
No, Federal Motor Vehicle Safety Standard 208 does not preempt a state tort suit alleging negligence for choosing a simple lap belt over a lap-and-shoulder belt for rear inner seats. The Court applies ordinary conflict preemption principles, which preempt a state law that "stands as an obstacle to the accomplishment and execution of the full purposes and objectives" of a federal law. This case is distinguished from Geier v. American Honda Motor Co., where a state tort suit was preempted because manufacturer choice among passive restraint devices (airbags vs. automatic seatbelts) was deemed a "significant objective" of an earlier version of FMVSS 208. In Geier, DOT deliberately sought a mix of devices to gather data, encourage innovation, and avoid public backlash, and a tort suit undermining this choice would obstruct a significant federal objective. However, in the present case, while the 1989 version of FMVSS 208 offers a choice for rear inner seats, the history and DOT's contemporaneous explanations indicate that manufacturer choice was not a "significant regulatory objective" for these seatbelts. DOT was not concerned about consumer acceptance, acknowledged that lap-and-shoulder belts would increase safety, and did not fear additional safety risks. Although cost-effectiveness was a factor, it was diminishing, and inferring preemption from every cost-effectiveness judgment would treat all federal standards as maximums, contradicting the statutory saving clause preserving common-law liability. The Solicitor General's consistent view that DOT's regulation does not preempt this tort suit further supports this conclusion, given the agency's unique expertise. Therefore, the state tort suit does not stand as an obstacle to the federal regulation's full purposes and objectives.
Concurring - Justice Sotomayor
Yes, I agree with the majority's conclusion that the state tort suit is not preempted. I write separately to clarify that Geier v. American Honda Motor Co. should not be broadly interpreted to mean that any time an agency provides manufacturers with a choice between options, a state tort suit that imposes liability based on one of those options is automatically preempted. Preemption based on manufacturer choice arises only when there is evidence that the agency has a specific regulatory objective, such as obtaining a mix of devices (as in Geier), whose achievement depends on manufacturers having the freedom to choose among those options. In this case, the agency did not provide strong indications that its safety goals required a mixture of seatbelt types for rear inner seats. In light of the statutory saving clause, which envisions a meaningful role for state tort law, the respondents have not demonstrated that manufacturer choice was a "significant federal regulatory objective" here.
Concurring - Justice Thomas
Yes, I concur in the judgment that the state tort lawsuit is not preempted, but I arrive at this conclusion through a more direct path: the plain text of the National Traffic and Motor Vehicle Safety Act's saving clause. The saving clause, 449 U.S.C. § 30103(e), explicitly states that "[c]ompliance with a motor vehicle safety standard prescribed under this chapter does not exempt a person from liability at common law." Since Mazda complied with FMVSS 208 by installing a lap belt, and the Williamsons' suit is a common-law tort action, the saving clause directly prevents preemption. I reiterate my rejection of "purposes-and-objectives preemption" as inconsistent with the Constitution. Preemption must arise from the explicit text of a federal statute or its authorized regulations, not from "extratextual 'judicial suppositions'" or an unconstrained inquiry into an agency's unstated intentions or "psychoanalysis" of regulators' past thoughts. The majority's detailed examination of agency history and reasoning, while characteristic of purposes-and-objectives preemption, is unnecessary and unconstitutional when the statutory text provides a clear answer.
Analysis:
This case significantly clarifies and narrows the scope of conflict preemption based on manufacturer choice, particularly as it relates to the precedent set in Geier v. American Honda Motor Co. It establishes that the mere existence of a federal regulation offering manufacturers options does not automatically trigger preemption of state tort claims. Instead, courts must conduct a more searching inquiry into whether the manufacturer's choice was a "significant regulatory objective" intended by the agency to achieve a specific federal purpose. The ruling reaffirms the vitality of the statutory saving clause and underscores the continued role of state common-law tort actions in areas not explicitly and intentionally displaced by federal regulatory objectives.
