Seat belts exist only to keep people safe, but the reality is that there are many occasions where safety belts seriously injure and even cause the deaths of those who obediently use them.
This is why the Williamson lawsuit was filed. It originates in a 2002 car crash where Thanh Williamson, 32, died while wearing a lap seat belt in a Mazda 1993 MPV minivan. Mazda argued that Williamson was setting in the center position of the rear passenger seat and at the time, the car maker was only required to provide a lap band for this spot per National Highway Traffic Safety Administration (NHTSA) regulation. Mazda’s defense isn’t that the seat belt wasn’t the cause of Mrs. Williamson’s death; instead, Mazda claimed it should not be liable because the nine (9) year old minivan was okay under federal regulations when it left the plant.
Last November, we considered the Mazda Seat Belt case because of its national importance. The U.S. Supreme Court had a big decision to make: whether or not to allow car manufacturers to avoid legal liability for these seat beat injuries and deaths because at the time the cars (or trucks or minivans) are made, they meet the minimum safety standards set by federal law.
Now, the United States Supreme Court has ruled. Unanimously. And, it’s a big deal for many reasons — but for those who care about people being safe in their cars, here’s why this week’s opinion is so important to us all: the High Court has told the American automobile industry that federal regulations were created only to set the minimum standard, not to provide the car makers with some kind of shield, or immunity, from legal responsiblity if their product harmed or killed their customers.
Of course, car makers are dismissing the major impact of this new Supreme Court decision to the public (like those explanations given to the Detroit News). However, read the entire Supreme Court opinion (with all the Justices in agreement, a rare showing of solidarity these days) in Cause No. 08-1314, styled Williamson v. Mazda Motor of America, Inc. and you will find language like this:
Federal Motor Vehicle Safety Standard 208 (1989 version) requires, among other things, that auto manufacturers install seat belts 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. 54 Fed. Reg. 46257–46258 (1989); 49 CFR §571.208 (1993), promulgated pursuant to the National Traffic and Motor Vehicle Safety Act of 1966 (Act), 80 Stat. 718, 15 U. S. C. §1381.
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 seat belt choice is not a significant objective of the federal regulation. Consequently, the regulation does not pre-empt the state tort suit.
[From Justice Sontemayor’s Concurrence, the following:]
In other words, the mere fact that an agency regulation allows manufacturers a choice between options is insufficient to justify implied pre-emption; courts should only find pre-emption where evidence exists that an agency has a regulatory objective— e.g., obtaining a mix of passive restraint mechanisms, as in Geier—whose achievement depends on manufacturers having a choice between options. A link between a regulatory objective and the need for manufacturer choice to achieve that objective is the lynchpin of implied pre-emption when there is a saving clause.