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Williamson v. Mazda: Vehicle Safety Gets Another Look by the Supreme Court

posted on Wed, Feb 2 2011 9:38 am by Jon S. Vernick

Vehicle Safety

Shortly after I graduated from law school in 1989, I bought my first new car.  It was a fairly modest affair – a silver 1989 Honda Civic with a stick shift – but I was very fond of it.

As it happened, my first post-law school job involved working to improve motor vehicle safety, so naturally enough I began to scrutinize my automotive purchase with a new set of eyes. I noticed that my car did not have air bags – not too many cars did at that time. I also noticed that the Civic had 3-point lap-shoulder belts in the two front bucket seats and also in both rear seats near the windows (these are called the outboard seats). But it had only a lap seat belt in the middle (inboard) position of the rear seat (the seat my two sisters and I would fight to avoid as kids).

In my new job, I soon learned that my car was actually a bit ahead of its time in supplying lap-shoulder belts in ANY of the rear seats – these were not required in passenger car rear outboard seats until 1991. I also learned that, although wearing seat belts clearly saves lives, there was also a long history of harm caused by lap-only belts to some occupants when, without the support of a shoulder belt, they can “jackknife” around the lap belt in certain crashes.

In November, the Supreme Court heard oral arguments in a case that brought back all of these memories for me. The facts of Williamson v. Mazda are especially sad.  In 2002, Delbert Williamson, his wife Thanh, and daughter Alexa were riding in the family’s 1993 Mazda MPV Minivan.  Delbert was driving; Thanh and Alexa were in the second row of seats, with Alexa wearing a lap-shoulder belt and Thanh next to her wearing the lap-only belt provided by Mazda. As the Williamsons were driving, a motor home towing a Jeep Wrangler approached them from the opposite direction. The Wrangler became detached and drifted into the Williamsons’ lane.  In the ensuing crash, Thanh Williamson was killed; Delbert and Alexa survived.

The Williamsons brought a lawsuit alleging that Mazda should be liable for failing to provide a lap-shoulder belt for the seat occupied by Thanh.  A California appellate court dismissed the case, ruling that because federal law gave Mazda the option of installing either a lap-shoulder or a lap-only belt in the inboard seating position occupied by Mrs. Williamson, the claim was preempted.

The court relied, in part, on an earlier case, Geier v. American Honda.  In Geier, the Supreme Court ruled that a claim alleging Honda should have provided airbags in a 1987 Honda Accord, at a time when federal rules permitted but did not require them, was similarly preempted.

Now in Williamson the Supreme Court, perhaps surprisingly, has given itself a chance to reconsider or perhaps clarify Geier. I say “surprisingly” because the Roberts court has a reputation among some as business friendly.

Today, motor vehicle traffic crashes are at their lowest levels in the U.S. since 1950. This remarkable success has been achieved through a variety of strategies, including: regulation, changes to social norms, voluntary action by car makers and – yes -- litigation. Yet more than 33,000 people still lost their lives on the nation’s roads in 2009, making traffic crashes the leading cause of death for Americans age 10-34.

CDC’s Director Dr. Tom Frieden has recently declared reducing motor vehicle injuries as one of several “winnable battles.” Legislators, health departments, police departments, advocates, manufacturers, consumers, and, once again, the Supreme Court have an opportunity to influence this fight.

Read an update on the court decision.


This information was developed by Jon S. Vernick, associate professor at the Johns Hopkins Bloomberg School of Public Health; deputy director of the Johns Hopkins Center for Injury Research and Policy; and partner of the Network for Public Health Law – Eastern Region.

The Network for Public Health Law provides information and technical assistance on issues related to public health. The legal information and assistance provided in this document does not constitute legal advice or legal representation. For legal advice, readers should consult a lawyer in their state.

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