On February 23, 2011, the Supreme Court issued its decision in Williamson v. Mazda. In an 8-0 ruling (Justice Kagan did not participate in the decision), the Court concluded that the Williamsons’ lawsuit was not preempted by the Federal Motor Vehicle Safety Standard (FMVSS) that permitted Mazda to install a lap-only seat belt in the rear aisle seat of the Williamsons’ mini-van. This means only that the lawsuit against Mazda may proceed, not that the Williamsons will necessarily prevail in that suit.
Writing for the court, Justice Breyer explained why this case was different from the Court’s prior Geier decision, which did find a lawsuit alleging that a Honda Accord was defective because it lacked an airbag to be preempted. In Geier, Breyer wrote, the Department of Transportation (DOT) thought that giving manufacturers a choice to install airbags versus other safety devices was an important regulatory objective to ensure that cars eventually were equipped with the best and safest safety systems. But DOT’s decision to allow manufacturers a choice to install lap belts versus lap-shoulder belts in rear inboard seating positions was not a significant regulatory objective and instead was motivated by cost-benefit and other concerns. For the Supreme Court in Williamson, this made all the difference. It meant that allowing a lawsuit against Mazda to proceed would not frustrate the purposes and objectives of the FMVSS.
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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.