In the recent case of Williamson v. Mazda Motor of America, 562 U.S.__(2011), the United States Supreme Court has held that the 1989 version of Federal Motor Vehicle Safety Standard 208 (FMVSS 208) giving vehicle manufacturers a choice to install either a lap belt or a lap and shoulder belt in a rear inner seat of a motor vehicle did not pre-empt a California state court case in which plaintiffs alleged that the absence of a lap and shoulder belt in the rear inner seat of their vehicle rendered it defective.
In 2002, the Williamson family, riding in their 1993 Mazda minivan, was struck head on by another vehicle. Thahn Williamson was seated in the rear aisle seat of the vehicle, and was killed despite wearing the installed lap belt while family members seated in the front seats and wearing lap and shoulder belts survived. Plaintiffs sued Mazda in state court in California, claiming that Mazda should have installed lap-and-shoulder belts and that failure to do so caused Thahn’s death. The state trial court dismissed the complaint, and the appellate court affirmed, relying on Geier v. American Honda Motor Co., 529 U.S. 861(2000) in which the Supreme Court found that an earlier version of FMVSS 208, requiring installation of passive restraint devices in motor vehicles, preempted a state court suit against an auto manufacturer for failure to install airbags.
In reversing, the Supreme Court noted that under ordinary conflict pre-emption principles, a state law that stands as an obstacle to the accomplishment of a federal law is preempted. According to the Court, in Geier, the state law stood as an obstacle to the accomplishment of a significant federal objective, namely, giving manufacturers a choice among different kinds of passive restraint systems. The history of FMVSS 208 showed that the U. S. Department of Transportation (DOT) had long considered it important to provide manufacturers with choices of alternative restraint systems, and that the challenged state action impeded that goal. In Williamson, the Court concluded that the regulation gives manufacturers a choice in restraint systems, and conceded that the challenged lawsuit would restrict the choice. However, the Court found, the choice at issue was not "a significant regulatory objective" because DOT’s stated objectives in giving manufacturers a choice between lap and shoulder belts or lap only belts for rear inner seats were rooted in cost-effectiveness and not in an effort to spur the development of alternative safety devices, the state court suit was found not to impede accomplishment of a federal law and was thus not preempted.
In view of Williamson, manufacturers seeking to repel state court actions based on preemption need to pay careful attention to the history and rationale behind the federal regulations on which they rely.