Williamson v. Mazda Motor of America

Congress enacted the Motor Vehicle Safety Act (“Safety Act”) in 1966 to reduce traffic accidents and deaths and injuries resulting from traffic accidents. See Brief for Petitioners, Delbert Williamson, et al. at 2; 49 U.S.C. § 30101. Under the Safety Act, the Secretary of Transportation has responsibility for prescribing motor vehicle safety standards. See 49 U.S.C. § 30111(a). The Secretary of Transportation assigned that responsibility to the National Highway Traffic Safety Administration (“NHTSA”). See Brief for Petitioners at 3. The NHTSA has responsibility for promulgating Federal Motor Vehicle Safety Standards (“FMVSS”). SeeId. With limited exceptions, all vehicles must conform to prescribed safety standards. See 49 U.S.C. 30112(a). One such standard, Standard 208, addresses seatbelt rules created to reduce fatalities and injuries from crashes. See Brief for Petitioners at 4–5.

The Safety Act does not allow a state or local government to preempt federal law by using a lower standard than one in the Safety Act. See 49 U.S.C. § 30103(b)(1). The Safety Act also includes a “savings clause” stating that compliance with a safety standard does not exempt a person from state common law liability. See 49 U.S.C. § 30103(e); Brief for Petitioners at 3. In Geier v. American Honda Motor Co., the Supreme Court held that the savings clause does not bar ordinary conflict preemption principles by which federal regulations trump conflicting state law. See Geier v. American Honda Motor Co., 529 U.S. 861, 869 (2000). The Court also found, however, that the savings clause did not save state-law tort actions directly in conflict with federal regulations. See Id. Direct conflict refers both to situations in which state law makes following a federal regulation impossible and situations in which following state law frustrates the purpose of a federal regulation. See Id. at 873–74.

In this case, Delbert Williamson is suing under state common law, alleging that the seatbelts used by Respondent Mazda Motor of America (“Mazda”) led to his wife’s death. See Brief for Petitioners at 18. Williamson argues that he can sue under California state tort law because the state’s tort law is not directly in conflict with the federal regulations in Standard 208. SeeId. at 26. Mazda claims that Geier requires the Court to find that the state law is preempted by federal law, because holding Mazda liable under state law would directly conflict with the federal objectives of Standard 208. See Brief for Respondents, Mazda Motor of America, et al., at 22–23.

Do the objectives of the NHTSA in enacting Standard 208 directly conflict with state tort claims?

Williamson argues that the purpose of Standard 208 is to provide only minimum standards for seatbelt safety. See Brief for Petitioners at 3; 49 U.S.C. § 30102(a)(9). He contends that these minimum standards give a manufacturer an option to exceed expectations by installing Type 2 seatbelts to better protect itself from liability. See Brief for Petitioners at 28.

Mazda contends that Standard 208 represent a policy judgment by the NHTSA to give manufacturers a choice in seatbelt options. See Brief for Respondents at 23–24. Mazda argues that the NHTSA did not give manufacturers a choice between seatbelts with the idea that Type 1 provided a bare minimum standard, but rather provided options because both Type 1 and Type 2 seatbelts have their own risks and benefits. SeeId. at 40–41. Mazda believes that under Williamson’s reasoning, a manufacturer could just as easily be liable for choosing to install a Type 2 seatbelt, putting manufacturers in an intolerable position with potential liability for following either option of a federal regulation. SeeId. at 41.

Williamson claims that NHTSA’s objective in passing the 1989 version of Standard 208 was to encourage manufacturers to install Type 2 seatbelts for all aisle seats in passenger vans. See Brief for Petitioners at 26. He asserts the original 1967 version of Standard 208 gave manufacturers the choice of whether to use Type 1 or Type 2 seatbelts in all rear seats, but required Type 2 seatbelts for all front outboard (within one foot of an interior wall) seats. SeeId. at 5. Williamson states that the NHTSA later found strong safety benefits associated with Type 2 seatbelts in rear seats for both adults and children, and acted on these findings by promulgating new regulations in 1989 to expand the Type 2 seatbelt requirement to rear outboard seats. SeeId. at 7–9. Williamson argues that the NHTSA did not require Type 2 seatbelts for rear aisle seats because of “technical difficulties,” and asserts that the NHTSA encouraged manufacturers to design and install Type 2 seatbelts in for rear aisle seats whenever they could overcome such difficulties. SeeId. at 11. Williamson asserts, however, that manufacturers had overcome the technical difficulties in installing rear aisle Type 2 seatbelts by the time Mazda manufactured the Williamson’s 1993 MPV minivan. SeeId. at 40–41. Therefore, Williamson believes that permitting state common law tort liability would advance the federal objective of encouraging manufacturers to install Type 2 seatbelts, even where not strictly required, to advance the ultimate federal goal of vehicle safety. SeeId.

Mazda argues that the Court must view the 1989 version of Standard 208 in light of the NHTSA’s entire history of Standard 208 seatbelt regulation, not just based on the objectives of the 1989 version. See Brief for Respondents at 25. Mazda asserts that the original version of Standard 208 gave manufacturers a choice between Type 1 and Type 2 seatbelts in all rear seats based on a balance of safety, technical feasibility, cost, and public acceptance. SeeId. at 29. For example, Mazda claims that throughout the 1989 rulemaking process NHTSA took into account that Type 2 seatbelts were unsafe for children. SeeId. at 30. Mazda also argues that if Williamson is correct that the NHSTSA encouraged the use of Type 2 seatbelts, this actually furthers Mazda’s belief that Standard 208 gave manufacturers a choice in seatbelts. SeeId. at 33. This is because the encouragement included the caveat that manufacturers should only use Type 2 belts when they could overcome the technical and safety problem of Type 2 seatbelts blocking aisles. SeeId.Therefore, Mazda believes federal policies that fully considered the competing factors and granted manufacturers a choice should preempt any state law claim aiming to take away that choice, such as Williamson’s claim. SeeId. at 37.

How does Geier affect a finding of preemption of Williamson’s state-law claim?

In Geier v. American Honda Motor Co., Inc., the Court found that the choice given by Standard 208 regulations on airbags preempted a state common-law tort claim that the automobile manufacturer should have used airbags regardless. See 529 U.S. at 864–65. Williamson distinguishes Geier from the current case by noting that Geier applied the 1984 version of Standard 208 governing airbag use in front positions, whereas this case concerns the 1989 version governing seatbelts in rear positions. See Brief for Petitioners at 12–13. Williamson contends that his lawsuit is consistent with Standard 208’s objective of encouraging manufacturers to install Type 2 seatbelts in rear aisle seats. See Id. at 26.

Mazda argues that the Court in Geier focused on the range of choices Standard 208 gave manufacturers based on cost concerns, safety and technological issues, and consumer acceptance. See Brief for Respondents at 20. According to Mazda, these concerns also motivated the seatbelt choice in the present case. See Id. at 29. Mazda claims that even though the Standard 208 section in Geier is not identical to that in the present case, the two cases are strikingly similar and the Court has not confined Geier to its facts but made a general pronouncement on the preemption of state-based motor vehicle claims. See Id. at 22.

Williamson also argues that the Geier Court took into account the Department of Transportation’s view that a lawsuit pressing for an airbag requirement would conflict with the objectives of Standard 208. See Brief for Petitioners at 30. Williamson says that the United States’ position represents a consistently narrow view of implied conflict preemption. See Id. In the present case, the United States maintains that Standard 208 does not represent a policy judgment that manufacturers should be free to choose between seatbelts, so Williamson’s suit does not conflict with any federal goals. See Brief of Amicus Curiae the United States of America in Support of Petitioners at 10.

Mazda counters that the United States’ position should not receive “special consideration” for several reasons, such as what, in Mazda’s opinion, is the clear regulatory history of the Standard 208 and contradictions between the NHSTA’s record and government claims. See Brief for Respondents at 48–50. Additionally, Mazda argues that the United States’ position is suspect, because the United States, for nearly a decade, allowed courts to find that Standard 208 preempted state tort actions on claims concerning the failure to install Type 2 seatbelts. See Id. at 49. Mazda believes such silence indicates that the government agreed with the lower courts, but only recently shifted their position due to political changes. See Id. at 49–50. Although such a shift is permitted, Mazda contends that these “new” positions must be viewed with suspicion. See Id. at 50.