Williamson v. Mazda Motor of America, Inc.

Last updated

Williamson v. Mazda Motor of America, Inc.
Seal of the United States Supreme Court.svg
Argued November 3, 2010
Decided February 23, 2011
Full case nameDelbert Williamson, et al., Petitioners v. Mazda Motor of America, Inc., et al.
Docket no. 08-1314
Citations562 U.S. 323 ( more )
131 S. Ct. 1131; 179 L. Ed. 2d 75; 78 U.S.L.W. 3687
Case history
Priordismissed (S.C.O.C 2008), affirmed (C.C.A. 2009), reversed, 562 U.S. 323(2011).
Holding
FMVSS 208 does not pre-empt state tort suits claiming that manufacturers should have installed lap-and-shoulder belts, instead of lap belts, on rear inner seats.
Court membership
Chief Justice
John Roberts
Associate Justices
Antonin Scalia  · Anthony Kennedy
Clarence Thomas  · Ruth Bader Ginsburg
Stephen Breyer  · Samuel Alito
Sonia Sotomayor  · Elena Kagan
Case opinions
MajorityBreyer, joined by Roberts, Scalia, Kennedy, Ginsburg, Alito, Sotomayor
ConcurrenceSotomayor
ConcurrenceThomas (in judgment)
Kagan took no part in the consideration or decision of the case.
Laws applied
National Traffic and Motor Vehicle Safety Act

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.

Contents

The case arose when Thanh Williamson died in a 2002 auto accident from seat-belt related injuries. Williamson's family filed suit against Mazda Motor of America in California state court, claiming a defective design leading to a wrongful death. However, the California trial court dismissed the suit on the pleadings, agreeing with Mazda that the action was preempted by federal law, and the California Court of Appeal affirmed the dismissal. The California Supreme Court declined to review the case, but the U.S. Supreme Court accepted the Williamson's petition for certiorari.

In a unanimous decision handed down on February 23, 2011, the Court unanimously (8-0, with Justice Elena Kagan not taking part in this case) reversed the California courts and held that federal preemption does not apply. Justice Stephen Breyer wrote the decision of the court. Justice Sonia Sotomayor wrote a concurring opinion, and Justice Clarence Thomas wrote an opinion concurring in the judgment.

Background

Dating back as early as 1885, seat belts were first patented by Edward J. Claghorn. In 1955, Ford began offering the lap belt in their automobiles. Saab then began to manufacture their entire range of automobiles with seat belts; most importantly the Saab GT750, launched in 1958. From this model, the practice of seat belt installation then became a competitive advantage to the industry but still did not seem essential to the consumers. Forward, this popular technique became standard in most U.S. automobiles. By 1965, front lap seat belts were produced in several models, by 1968 front shoulder and rear lap belts were introduced, and in 1974 three point front lap belts were adopted in most automobiles. The first United States Federal law pertaining to the use of seat belts became effective January 1, 1968 with the help of the U.S. Department of Transportation which was created two years prior. The law has since been modified but currently requires all vehicles to be produced with three-point seat belts in all seating areas. The use and legality of seat belts varies from state to state, with the first state to pass the law requiring all passengers to wear a seat belt being New York on December 1, 1984. Currently, there are no countries whose automobiles do not offer seat belts and it is a standardized practice worldwide. [1]

During the development of the seat belt, the federal legislation created several agencies responsible for automobile and road safety: The National Traffic Safety Agency, the National Highway Safety Agency, and the National Highway Safety Bureau, which were merged by the 1970 Highway Safety Act into the combined National Highway Traffic Safety Administration (NHTSA).

The NHTSA was authorized to promulgate regulations - the Federal Motor Vehicle Safety Standards (FMVSS) - which provide standards that auto makers must follow in order to allow vehicles to be imported. Of the 68 FMVSS, two standards, 208 and 209, were implemented to standardize lap and shoulder belts in front seating positions as well as lap belts in all other positions in the vehicle. [2]

Facts of the case

On the evening of August 14, 2002, the Williamson family driving in their 1993 Mazda MPV minivan, were struck by a Jeep Wrangler from the opposite direction. The Jeep was being towed by a motor home and came loose, crossing over into the Williamson's lane and causing a head-on collision. Delbert Williamson, the petitioner, was driving, while his wife Thanh and daughter Alexa were seated in the first row of seats behind him. Each passenger was wearing the appropriate seat belt per position. Delbert and Alexa were equipped with Type 2 seat belts which consist of lap and shoulder restraints. Thanh, seated in a middle position, was only equipped with a Type 1 seat belt which consists of just a lap belt. As the vehicles collided, Thanh's body was said to "jackknife" over her lap belt, causing internal bleeding and eventual fatal injuries. Delbert and his daughter Alexa both survived the accident because of the type 2 seat belt they were able to use in their seated position. [3]

California state court

The survivors, Delbert and Alexa, brought the tort suit against Mazda in a California state court claiming that the van had a defective design because it was equipped with lap-only seat belts in the back seats, including where Thanh was sitting. Mazda responded with an argument in regards to the 1989 version of FMVSS 208 which preempted any state law tort claims and that the plaintiffs could not argue their product liability claim in court. The company asserted that FMVSS 208 permits manufacturers to install either Type 1 or Type 2 safety restraints in rear aisle seats. They also claimed that a state law permitting attached liability to manufacturers within this standard conflicts with federal laws. Mazda argued that the suit was barred under federal preemption, a doctrine derived from the Supremacy Clause of the United States Constitution that provides that state law must yield to federal law when the two conflict. On October 22, 2008, the California trial court ruled in favor of Mazda, dismissing the Williamsons' claims. [4]

Williamson appealed the trial court's dismissal of the suit on February 11, 2009, to the California Court of Appeal, but that court affirmed the lower court's decision, relying on Geier v. American Honda Company (2000), in which the U.S. Supreme Court held that the 1984 FMVSS 208 preempted state law claims for car accident injuries due to design. In Williamson's case, the lawsuit also conflicted with Standard 208 and preempted state law claims.

The Williamson petitioned the California Supreme Court to hear the case, but the court declined review.

Supreme Court

Following the California Supreme Court's denial of review, the family petitioned the U.S. Supreme Court for certiorari, which was granted on May 24, 2010. [5]

On February 23, 2011, the Court reversed the decision of the California state court by a unanimous 8-0 vote; the Court ruled that FMVSS 208 does not preempt state law claims, distinguishing from the prior decision made in Geier . The opinion of Justice Elena Kagan was found to be extremely persuasive stating that the lower courts had broadly interpreted federal regulations regarding FMVSS 208, but later had no part in the consideration of the case. The reasoning for this decision was based on the fact that automobile manufacturers had the choice to install airbags in the 1984 version of the law. When it came to developing seatbelt standards in the 1989 version of FMVSS 208, there were concerns about the loss of effectiveness. With this concern, the court was able to conclude that there was no basis to demonstrate the intent of preemption in state law claims by federal auto safety standards. The court distinguished this decision from Geier v. American Honda Motor Co. because, unlike in Geier, the state law did not conflict with the federal statute's purposes, as there was no experiment or gradual implementation component in the seatbelt provision. A legal provision for FMVSS 208 was then enacted in September 2007 requiring vehicles to have lap and shoulder belts for all seats in the rear of the vehicle. [6]

Problems with preemption

Courts have struggled to define a consistent theory on preemption, and opinions differ on to how and to what extent legislative history ought to be used. [7]

See also

Related Research Articles

<span class="mw-page-title-main">Seat belt</span> Vehicle safety device to protect against injury during collisions and sudden stop

A seat belt, also known as a safety belt or spelled seatbelt, is a vehicle safety device designed to secure the driver or a passenger of a vehicle against harmful movement that may result during a collision or a sudden stop. A seat belt reduces the likelihood of death or serious injury in a traffic collision by reducing the force of secondary impacts with interior strike hazards, by keeping occupants positioned correctly for maximum effectiveness of the airbag, and by preventing occupants being ejected from the vehicle in a crash or if the vehicle rolls over.

<span class="mw-page-title-main">Automotive safety</span> Study and practice to minimize the occurrence and consequences of motor vehicle accidents

Automotive safety is the study and practice of automotive design, construction, equipment and regulation to minimize the occurrence and consequences of traffic collisions involving motor vehicles. Road traffic safety more broadly includes roadway design.

<span class="mw-page-title-main">School bus</span> Bus operated by a school or school district for student transport

A school bus is any type of bus owned, leased, contracted to, or operated by a school or school district. It is regularly used to transport students to and from school or school-related activities, but not including a charter bus or transit bus. Various configurations of school buses are used worldwide; the most iconic examples are the yellow school buses of the United States which are also found in other parts of the world.

The National Highway Traffic Safety Administration is an agency of the U.S. federal government, part of the Department of Transportation, focused on transportation safety in the United States.

The National Traffic and Motor Vehicle Safety Act was enacted in the United States in 1966 to empower the federal government to set and administer new safety standards for motor vehicles and road traffic safety. The Act was the first mandatory federal safety standards for motor vehicles. The Act created the National Highway Safety Bureau. The Act was one of a number of initiatives by the government in response to increasing number of cars and associated fatalities and injuries on the road following a period when the number of people killed on the road had increased 6-fold and the number of vehicles was up 11-fold since 1925. The reduction of the rate of death attributable to motor-vehicle crashes in the United States represents the successful public health response to a great technologic advance of the 20th century—the motorization of the United States.

<span class="mw-page-title-main">California Department of Motor Vehicles</span> State agency in the United States

The California Department of Motor Vehicles (DMV) is the state agency that registers motor vehicles and boats and issues driver licenses in the U.S. state of California. It regulates new car dealers, commercial cargo carriers, private driving schools, and private traffic schools. The DMV works with the superior courts of California to promptly record convictions against driver licenses, and initiates administrative proceedings before its own administrative law judges to suspend or revoke licenses when drivers accumulate excessive convictions. It issues California license plates and driver's licenses. The DMV also issues identification cards to people who request one.

<span class="mw-page-title-main">Seat belt laws in the United States</span>

Most seat belt laws in the United States are left to state law. However, the recommended age for a child to sit in the front passenger seat is 13. The first seat belt law was a federal law, Title 49 of the United States Code, Chapter 301, Motor Safety Standard, which took effect on January 1, 1968, that required all vehicles to be fitted with seat belts in all designated seating positions. This law has since been modified to require three-point seat belts in outboard-seating positions, and finally three-point seat belts in all seating positions. Seat belt use was voluntary until New York became the first state to require vehicle occupants to wear seat belts, as of December 1, 1984. New Hampshire is the only state with no law requiring adults to wear seat belts in a vehicle.

The Federal Motor Vehicle Safety Standards (FMVSS) are U.S. federal vehicle regulations specifying design, construction, performance, and durability requirements for motor vehicles and regulated automobile safety-related components, systems, and design features. They are the U.S. counterpart to the UN Regulations developed by the World Forum for Harmonization of Vehicle Regulations and recognized to varying degree by most countries except the United States.

<span class="mw-page-title-main">American Trucking Associations</span> Federation of trucking industry groups

The American Trucking Associations (ATA), founded in 1933, is the largest national trade association for the trucking industry. ATA represents more than 37,000 members covering every type of motor carrier in the United States through a federation of other trucking groups, industry-related conferences, and its 50 affiliated state trucking associations. Former Governor of Kansas Bill Graves was replaced by Chris Spear as the ATA's president and CEO in July 2016.

<span class="mw-page-title-main">Miles Electric Vehicles</span> All-electric vehicle manufacturer and distributor

Miles Electric Vehicles was a manufacturer and distributor of all-electric vehicles manufactured by FAW Tianjin in China that met international car safety standards. Miles was given the "Electric Car Company of 2007" award by Good Clean Tech. The company filed for bankruptcy on June 11, 2013.

FDA preemption is the legal theory in the United States that products licensed or otherwise approved for use by the Food and Drug Administration (FDA) are exempt from various state efforts to preclude their use. It has been raised as a counter to both direct efforts to ban such products, and as a defense against tort claims regarding such products. The doctrine hinges on the assertion of Congressional intent to designate FDA as the national clearinghouse for determinations of the safety of pharmaceutical products, and the Supremacy Clause of the Constitution of the United States placing federal law over state law.

Wyeth v. Levine, 555 U.S. 555 (2009), is a United States Supreme Court case holding that Federal regulatory approval of a medication does not shield the manufacturer from liability under state law.

When a person makes a claim for personal injury damages that have resulted from the presence of a defective automobile or component of an automobile, that person asserts a product liability claim. That claim may be against the automobile's manufacturer, the manufacturer of a component part or system, or both, as well as potentially being raised against companies that distributed, sold or installed the part or system that is alleged to be defective.

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. 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.

In the law of the United States, federal preemption is the invalidation of a U.S. state law that conflicts with federal law. The rules of preemption seek to restrict it to only where it is explicit or necessary. In the course of adjudicating cases, the issue of preemption may be heard in either state or federal court.

The Supremacy Clause of the Constitution of the United States establishes that the Constitution, federal laws made pursuant to it, and treaties made under its authority, constitute the "supreme Law of the Land", and thus take priority over any conflicting state laws. It provides that state courts are bound by, and state constitutions subordinate to, the supreme law. However, federal statutes and treaties must be within the parameters of the Constitution; that is, they must be pursuant to the federal government's enumerated powers, and not violate other constitutional limits on federal power, such as the Bill of Rights—of particular interest is the Tenth Amendment to the United States Constitution, which states that the federal government has only those powers that are delegated to it by the Constitution. It is the responsibility of the United States Supreme Court in that case to exercise the power of judicial review: the ability to invalidate a statute for violating a provision of the Constitution.

Motor Vehicle Manufacturers Association v. State Farm Mutual Automobile Insurance Co., 463 U.S. 29 (1983), commonly known in U.S. administrative law as State Farm, is a United States Supreme Court decision concerning regulations requiring passive restraints in cars. Decided in 1983, one year before Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., the Court found that the National Highway Traffic Safety Administration had not provided a "reasoned analysis" for rescinding regulations that required either airbags or automatic seat belts in new cars.

The misappropriation doctrine is a U.S. legal theory conferring a "quasi-property right" on a person who invests "labor, skill, and money" to create an intangible asset. The right operates against another person "endeavoring to reap where it has not sown" by "misappropriating" the value of the asset. The quoted language and the legal principle come from the decision of the United States Supreme Court in International News Service v. Associated Press, 248 U.S. 215 (1918), also known as INS v. AP or simply the INS case.

Federal Motor Vehicle Safety Standard 208 regulates automotive occupant crash protection in the United States. Like all other Federal Motor Vehicle Safety Standards, FMVSS 208 is administered by the United States Department of Transportation's National Highway Traffic Safety Administration.

Increases in the use of autonomous car technologies are causing incremental shifts in the responsibility of driving, with the primary motivation of reducing the frequency of traffic collisions. Liability for incidents involving self-driving cars is a developing area of law and policy that will determine who is liable when a car causes physical damage to persons or property. As autonomous cars shift the responsibility of driving from humans to autonomous car technology, there is a need for existing liability laws to evolve to reasonably identify the appropriate remedies for damage and injury. As higher levels of autonomy are commercially introduced, the insurance industry stands to see higher proportions of commercial and product liability lines of business, while the personal automobile insurance line of business shrinks.

References

  1. "The History of Seat Belt Development". School Transportation News. Retrieved March 14, 2012.
  2. "National Highway Traffic Safety Administration". Archived from the original on April 12, 2012. Retrieved March 14, 2012.
  3. Halford, Kelly. "Williamson v Mazda Motor of America (08-1314)". Legal Information Institute, Cornell University Law School. Retrieved March 14, 2012.
  4. Eisenberg. "U.S. Supreme Court Decides Seat Belt Case". Philadelphia Personal Injury Lawyers. Retrieved March 21, 2012.
  5. "Williamson et al. v Mazda Motor of America, Inc., et al" (PDF). Supreme Court of the United States. Retrieved March 21, 2012.
  6. Levy, Douglas (2011). U.S. Supreme Court ruling says even with federal standards offering choice, state tort suits not preempted. LegalTrac: Michigan Lawyers Weekly.
  7. Hylton, Keith (January 2011). "An Economic Perspective on Preemption". Boston Univ. School of Law Working Paper No. 11-03. SSRN   1747120.