Williamson v. Mazda Motor of America, Inc.

PETITIONER: Delbert Williamson, et al.
RESPONDENT: Mazda Motor of America, Inc., et al.
LOCATION: Superior Court of California, Superior Justice Center

DOCKET NO.: 08-1314
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: State appellate court

CITATION: 562 US (2011)
GRANTED: May 24, 2010
ARGUED: Nov 03, 2010
DECIDED: Feb 23, 2011

ADVOCATES:
Gregory G. Garre - for the respondents
Martin N. Buchanan - on behalf of the petitioners
William M. Jay - Assistant to the Solicitor General, Department of Justice, for the United States as amicus curiae supporting the petitioners

Facts of the case

Three members of the Williamson family were involved in a head-on collision with another vehicle. Delbert and Alexa wore lap/shoulder seatbelts and survived, while Thanh wore a lap-only seatbelt and died. Subsequently, they sued Mazda Motor of America for strict products liability, negligence, deceit, and wrongful death in a California state court. The court dismissed the claims, holding that federal law precluded a state court tort action "to the extent the theory of liability [was rooted in] the lap-only seat belt." On appeal, a California appellate court affirmed, holding that the National Highway Traffic Safety Administration ("NHTSA") regulation allowing minivan rear seats to have either lap-only or lap/shoulder seat belts preempted state court wrongful death actions.

Question

Does the NHTSA regulation allowing vehicle manufacturers to install either lap-only or lap/shoulder seatbelts in certain seating positions impliedly preempt a state-law claim alleging that the manufacturer should have installed lap/should seatbelts in one of its seating positions?

Media for Williamson v. Mazda Motor of America, Inc.

Audio Transcription for Oral Argument - November 03, 2010 in Williamson v. Mazda Motor of America, Inc.

Audio Transcription for Opinion Announcement - February 23, 2011 in Williamson v. Mazda Motor of America, Inc.

Stephen G. Breyer:

This case arises out of an auto accident.

The passenger sitting in the backseat of a minivan at the isle was killed.

The survivor brought tort suit in the California State Court and their argument was that the manufacture should have installed a lap-and-shoulder belts in that backseat and not just lap belts which is what was installed.

The California Court said that state tort liability based on that theory was preempted by the Department of Transportation Regulation, its Federal Motor Vehicle Safety Standard 208 which we've considered before and that particular standard said that manufacturers have to install seatbelts in the back of the minivan, but the belts can be either lap-and-shoulder belts or simple lap belts.

Now, the California Court said, "Well, that rule preempts the tort suit because the tort suit would takeaway from the manufacturer, the choice that the regulation gave him."

And since it conflicts with the federal regulation, the federal law prevails and the state tort suit is out.

Now, in holding that, the California Court relied on a case of this Court called Geier.

In Geier we consider that same regulation but a different part and the part we considered required manufacturers to install some kind of a passive restraint system.

But like this, it gave them a choice of system and say, “Airbags or automatic seatbelts or something else.”

And in that case, we said that regulation preempted a lawsuit against the manufacturer.

That case involved the suit which said you have to install airbags.

And the manufacturer said, "No,” it says, "I can install either airbags or seatbelt or some other things.”

And we said it was preempted.

Because we look at the regulation's history and we look at the agencies explanation of the regulation and we look at their current understanding.

And on that basis, we thought, "Well, they really do want to give the manufacturers of choice, that's an insignificant object of this regulation.”

The agency thinks that by giving them a choice, they'll get better safety regulation and that's up to them so it's preempted.

Now, we do hear just what we did in Geier.

We look at the history, the explanation, the purposes, why did they do it, and after doing the same kind of examination, we come to the opposite conclusion.

Because here, we think that the history and the agency's explanation, and their current understanding of the whole thing showed that indeed they did allow the manufacturers to have a choice between lap belts and lap-and-shoulder belts, but that was not a significant objective of what they were trying to do.

They had nothing to do with, didn't have much to do anyway with the safety concerns but rather that choice simply reflected an agency judgment about comparative cause and benefits and that here, just wasn't sufficient to show.

They thought it was so important that the states can't reach a different decision.

As far as we could tell, from looking at the history and the background and everything, they wouldn't have cared that states reached a different decision.

So, for that reason, we conclude that state tort law here does not stand as an obstacle to achieving an important federal objective.

The choice wasn't that important.

The state lawsuit is not preempted.

The judgment of the California Court is reversed.

Justice Sotomayor has filed a concurring opinion, Justice Thomas has filed an opinion concurring in the judgment and Justice Kagan took no part in the consideration or decision of this case.