Geier v. American Honda Motor Company, Inc.

PETITIONER: Geier
RESPONDENT: American Honda Motor Company, Inc.
LOCATION: Skagit County Superior Court

DOCKET NO.: 98-1811
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the District of Columbia Circuit

CITATION: 529 US 861 (2000)
ARGUED: Dec 07, 1999
DECIDED: May 22, 2000

ADVOCATES:
Arthur H. Bryant - Argued the cause for the petitioners
Lawrence G. Wallace - Argued the cause for the United States, as amicus curiae, by special leave of court, supporting the respondents
Malcolm E. Wheeler - Argued the cause for the respondents

Facts of the case

The Department of Transportation, under the National Traffic and Motor Vehicle Safety Act of 1966 (Act), promulgated Federal Motor Vehicle Safety Standard (FMVSS) 208, which required auto manufacturers to equip some of their 1987 vehicles with passive restraints. To comply with FMVSS 208, Honda installed manual seat belts and a warning light, instead of a driver-side airbag, for the 1987 Honda Accord. Alexis Geier suffered severe head and facial injuries in an accident while driving a 1987 Honda Accord that did not have a driver-side airbag. Geier and her parents sought damages under District of Columbia tort law, claiming that American Honda Motor Company was negligent in not equiping 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 because a jury verdict in Geier's favor "might establish a safety standard that was not identical to Standard 208." In affirming, the Court of Appeals concluded that, because Geier's state tort claims posed an obstacle to the accomplishment of the objectives of FMVSS 208, those claims conflicted with that standard and that the Act consequently pre-empted the lawsuit.

Question

Does the National Traffic and Motor Vehicle Safety Act of 1966 pre-empt a tort action in which the plaintiff claims that the defendant auto manufacturer, who was in compliance with the safety standard promulgated under the Act, should nonetheless have equipped an automobile with airbags?

Media for Geier v. American Honda Motor Company, Inc.

Audio Transcription for Oral Argument - December 07, 1999 in Geier v. American Honda Motor Company, Inc.

Audio Transcription for Opinion Announcement - May 22, 2000 in Geier v. American Honda Motor Company, Inc.

William H. Rehnquist:

The opinion of the Court in No. 98-1811, Geier versus American Honda Motor Company will be announced by Justice Breyer.

Stephen G. Breyer:

This case involves a tort plaintiff who was hurt while she was driving a 1987 Honda Accord equipped with seat belts which she had buckled up at the time of the accident.

She bases her claim on the theory that the car should have been equipped with airbags as well; and the legal question is whether federal law, in particular a 1984 National Highway Transportation Safety Act standard called the “Passive Restraint” standard, whether that forbids in effect the bringing of this kind of State Court tort suit.

In other words, does federal law preempt the suit?

The District Court found that it did preempt the suit; so the plaintiff couldn’t bring it.

And like other Federal Courts that have considered similar matters, the United States Court of Appeals for the District of Columbia Circuit agreed.

But some State Courts have taken a different view, and so we agreed to hear the case to resolve the differences.

Now, it is a complicated case and we answer three separate questions: first, there is an express preemption provision in the National Highway Transportation Safety Act.

Does that express preemption provision, preempt this lawsuit?

And we read that preemption provision in light of another provision which saves certain tort suits; and read that way, we say the answer is, “No, it does not expressly preempt a suit.”

Then the second question is, well, what about that Savings Clause?

Does that Savings Clause really require the opposite?

Does it preserve in some way or other, state tort suits like this one?

Again, we say the answer is ‘No.’

What we think applies, are just ordinary preemption principles.

Alright third; using those ordinary preemption principles -- those principles by the way require, or say, state that a federal regulation will preempt a state common law tort action -- either you can’t bring it -- if that tort action actually conflicts with the regulation.

So we have to decide using that principle is there an actual conflict here?

Now, after going into the history of the regulation in some detail, we conclude that there is an actual conflict.

The regulation in our view was designed to promote safety by producing a mix of different passive restraint devices, not just airbags; and moreover, that mix was to be introduced gradually over time, and the agency had safety related and administrative reasons for doing that.

And we think that petitioner’s tort suit, which in effect, would insist upon immediate introduction and uniform introduction of airbags would stand as an obstacle to achieving that safety objective, at least as the agency understood that and embodied it in the regulation.

For these reasons which we elaborate in our opinion, we agree with the lower Federal Courts that the regulation, and therefore the Act preempts this tort suit.

Justice Stevens has filed a dissenting opinion in which Justice Souter, Justice Thomas and Justice Ginsburg joined.