Geier v. American Honda Motor Company | |
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Argued December 7, 1999 Decided May 22, 2000 | |
Full case name | Alexis Geier, et al., petitioners v. American Honda Motor Company, Inc., et al. |
Citations | 529 U.S. 861 ( more ) 120 S. Ct. 1913; 146 L. Ed. 2d 914; 2000 U.S. LEXIS 3425; 68 U.S.L.W. 4425; CCH Prod. Liab. Rep. ¶ 15,795; 2000 Cal. Daily Op. Service 5277; 2000 Daily Journal DAR 5277; 2000 Colo. J. C.A.R. 2826; 13 Fla. L. Weekly Fed. S 344 |
Case history | |
Prior | Dismissed, (D.D.C. 1997); affirmed, 166 F.3d 1236 (D.C. Cir. 1999); cert. granted, 527 U.S. 1063(1999). |
Holding | |
The Federal standards for motor vehicle pre-empts tort lawsuits made under stricter state legislations. | |
Court membership | |
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Case opinions | |
Majority | Breyer, joined by Rehnquist, O'Connor, Scalia, and Kennedy |
Dissent | Stevens, joined by Souter, Thomas, Ginsburg |
Laws applied | |
National Traffic and Motor Vehicle Safety Act |
Geier v. American Honda Motor Company, 529 U.S. 861 (2000), was a United States Supreme Court case in which the Court held that a federal automobile safety standard pre-empted a stricter state rule. [1] The Court held that Alexis Geier, who suffered severe injuries in a 1987 Honda Accord, could not sue Honda for failing to install a driver-side airbag – a requirement under District of Columbia tort law but not Federal law – because Federal law pre-empted the District's rule.
Alexis Geier suffered severe injuries in a 1987 Honda Accord that did not possess a driver's side airbag. Geier and her family sought damages under the District of Columbia tort law "claiming that American Honda Motor Company was negligent in not equipping the Accord with a driver's side airbag." The District Court ruled in favor of Honda finding that "Geier's claims were expressly pre-empted by the Act." and created a conflict because the safety features of the 1987 Honda Accord were in compliance with Federal Vehicle Safety Standard (FMVSS) 208, under the National Traffic and Motor Vehicle Safety Act of 1966. [2] The United States Court of Appeals for the District of Columbia Circuit affirmed. [3]
Justice Stephen G. Breyer delivered the Court's 5–4 decision, which held: "[Geier's] 'no airbag' lawsuit conflicts with the objectives of FMVSS 208 and is therefore pre-empted by the Act." [4] The dissent challenged the majority's "unprecedented use of inferences from regulatory history and commentary as a basis for implied pre-emption." [5]
An airbag is a vehicle occupant-restraint system using a bag designed to inflate extremely quickly, then quickly deflate during a collision. It consists of the airbag cushion, a flexible fabric bag, an inflation module, and an impact sensor. The purpose of the airbag is to provide a vehicle occupant with a soft cushioning and restraint during a collision. It can reduce injuries between the flailing occupant and the interior of the vehicle.
A crash test is a form of destructive testing usually performed in order to ensure safe design standards in crashworthiness and crash compatibility for various modes of transportation or related systems and components.
The National Highway Traffic Safety Administration is an agency of the U.S. federal government, part of the Department of Transportation. It describes its mission as "Save lives, prevent injuries, reduce vehicle-related crashes" related to transportation safety in the United States.
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Reno v. Condon, 528 U.S. 141 (2000), was a case in which the Supreme Court of the United States upheld the Driver's Privacy Protection Act of 1994 (DPPA) against a Tenth Amendment challenge.
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Geier is a common surname in Germany and somewhat less common among German-American people. It is also found as a French surname, and as Russian surname. The latter probably is associated with German emigration to Russia in the 17th and 18th centuries. The surname Geier is often considered to be interchangeable with Geyer, although some sources ascribe a different origin and meaning to the two surnames. German migrants to English-speaking countries often Anglicize Geier as Geyer, though this change has become less common in recent years. Similarly, Geier has often been mistakenly changed to Geyer, and vice versa in legal papers such as birth certificates and migration documents, especially in areas where the name is uncommon, or one version is vastly prevalent.
Williamson v. Mazda Motor of America, Inc., 562 U.S. 323 (2011), was a decision by the Supreme Court of the United States, in which the Court unanimously held that Federal Motor Vehicle Safety Standard 208, promulgated by the National Highway Traffic Safety Administration, does not federally preempt state tort lawsuits against auto manufacturers from injuries caused by a defective lack of certain types of seat belts.
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The sixth generation Honda Accord was available as a four-door sedan or a two-door coupe and was produced by Honda from September 1997 to 2002 and from 1998 to 2003 in Europe.