On February 23, 2011 the U.S. Supreme Court issued its opinion in Williamson v. Mazda Motor of America, Inc. The Court considered whether federal regulations governing vehicle safety standards preempt state product liability claims for failure to install three-point, lap-and-shoulder style seat belts in the back seats of vehicles. In a unanimous decision, the Court held that such state claims were not barred, allowing litigation against Mazda to continue.
Background
The claims in Williamson arose from a 2004 car crash involving a 1993 Mazda MPV mini-van. Thanh Williamson was riding in the back seat of the van, which was equipped with a lap-style seat belt. Her husband Delbert and daughter Alexa were in the front seat, and were both wearing lap and shoulder seat belts. Delbert and Alexa survived the crash and brought suit against Mazda, claiming that the van was defectively designed because it had only lap-style seat belts in the back seats. Mazda argued that the 1989 version of Federal Motor Vehicle Safety Standard (FMVSS) 208 preempted any state law tort claims and the plaintiffs could not bring their product liability claim.
The California trial court agreed with Mazda that the federal regulations preempted state law claims and dismissed the suit. The California Court of Appeals affirmed the lower court's decision, reasoning that the U.S. Supreme Court's past decision in Greier v. American Honda Motor Corp. was controlling. In Greier, the Court held that the 1984 version of FMVSS 208 preempted state law claims for injuries sustained in car accidents where the car did not have an airbag, was controlling in this case.
U.S. Supreme Court Decision
The U.S. Supreme Court reversed the California court's decision, stating that FMVSS 208 did not preempt state law claims. The Court reasoned that giving automakers a choice about whether to install airbags was a significant objective of the 1984 version of the law. When setting the seat belt standards in the 1989 version of FMVSS 208, however, lawmakers were concerned about lost effectiveness. The Court concluded that this concern did not demonstrate the same intent to preempt state law claims.
The Court also found the opinion that Justice Elena Kagan issued while she was U.S. Solicitor General to be persuasive. Kagan had argued that the lower courts had interpreted the federal regulations too broadly and that FMVSS 208 was merely a minimum standard auto makers needed to meet.
Implications of the Decision for Car Accident Victims
According to Public Justice, a public interest law firm which contributed an amicus brief arguing against preemption to this case, the Supreme Court's decision in Williamson will benefit car accident victims. It will remove one of the defenses auto manufacturers frequently use to avoid liability for people injured in car accidents - that the claim is preempted by federal law - by limiting the application to Geier to its facts. The decision in Willimason will allow more people to recover damages for injuries sustained in car accidents with lap-belt only seat belts in the rear seats.
Thankfully, safety regulations have changed after September 2007 and most vehicles must now have lap and shoulder belts for all seats in the rear of the vehicle. The decision in Williamson is still important, however, because more than one million vehicles remain on the road in the U.S. with lap only belts in the rear passenger seats.
If you have been injured in an auto accident because you believe the vehicle you were in was defectively designed, do not hesitate to contact an experience attorney to discuss your situation and the compensation to which you may be entitled.
