Wednesday, February 23, 2011

Today's SCOTUS Decision in Williamson v. Mazda: More on Federal Preemption of State Tort Claims

Following up on yesterday’s decision in Bruesewitz v. Wyeth, the Supreme Court issued another decision on preemption today: Williamson v. Mazda (covered earlier here). Justice Breyer wrote the Opinion of the Court, which begins:

Federal Motor Vehicle Safety Standard 208 (1989 version) requires, among other things, that auto manufacturers install seatbelts on the rear seats of passenger vehicles. They must install lap-and-shoulder belts on seats next to a vehicle's doors or frames. But they have a choice about what to install on rear inner seats (say, middle seats or those next to a minivan's aisle). There they can install either (1) simple lap belts or (2) lap-and-shoulder belts.

The question presented here is whether this federal regulation pre-empts a state tort suit that, if successful, would deny manufacturers a choice of belts for rear inner seats by imposing tort liability upon those who choose to install a simple lap belt. We conclude that providing manufacturers with this seatbelt choice is not a significant objective of the federal regulation. Consequently, the regulation does not pre-empt the state tort suit.

The Court distinguished Geier v. American Honda Motor, 529 U.S. 861 (2000), which had held that a similar regulation preempted state tort law: “In Geier, . . . the regulation’s history, the agency’s contemporaneous explanation, and its consistently held interpretive views indicated that the regulation sought to maintain manufacturer choice in order to further significant regulatory objectives. Here, these same considerations indicate the contrary.”

Justice Sotomayor joined Justice Breyer’s opinion but also wrote a separate concurrence “to emphasize the Court's rejection of an overreading of Geier that has developed since that opinion was issued.”

Justice Thomas did not join Justice Breyer’s opinion but concurred in the judgment. His concurring opinion begins: “The Court concludes that the National Traffic and Motor Vehicle Safety Act of 1966 (Safety Act) and Federal Motor Vehicle Safety Standard 208 (FMVSS 208) do not pre-empt the Williamsons' state tort lawsuit. I agree. But I reach this result by a more direct route: the Safety Act's saving clause, which speaks directly to this question and answers it.” In reaching this conclusion, Justice Thomas reiterated his view that “[p]urposes-and-objectives pre-emption -- which by design roams beyond statutory or regulatory text -- is . . . wholly illegitimate.”

Justice Kagan took no part in the case.


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