Complying With Federal Safety Regulations Does Not Excuse Car Manufacturers

May 08, 2011

Complying With Federal Safety Regulations Does Not Excuse Car Manufacturers

The United States Supreme Court recently issued an opinion that opens the door to personal injury and wrongful death lawsuits against car manufacturers under state law. The ruling against Mazda Motor of America came after the family of a woman killed in an motor vehicle accident involving a minivan sued Mazda in state court. The family claimed that Mazda was negligent in failing to install rear seat lap-and-shoulder seatbelts that could have prevented the woman's fatal injuries. Mazda argued that the wrongful death lawsuit should be dismissed because it had complied with the Federal Motor Vehicle Safety Standards (FMVSS) in effect at the time the minivan was manufactured.

Specifically, Mazda noted that the FMVSS that regulated seatbelt installation only required the automobile manufacturer to install a lap belt in the middle seat of the second aisle of the minivan -- not a shoulder-and-lap belt as were required in the front, back, and side seats adjacent to the exterior of the vehicle. Thus, Mazda argued that it had no duty to install the lap-and-shoulder safety restraint in the middle seat, and that its compliance with the federal safety regulations preempts any state law claims of personal injury or wrongful death.

While a previous Supreme Court decision that addressed a similar claim against Honda Motor Corp. went in favor of the automaker, this time, the majority agreed with the plaintiff. While Mazda may have complied with Federal Motor Vehicle Safety Standards in place at the time the Mazda minivan was manufactured, the family of the woman killed in the high-impact collision could still sue the car manufacturer for negligence in state court.

The young mother of three was killed while sitting in the middle seat of the second aisle and restrained by a lap belt, but other family members in the minivan survived the minivan accident. They were all restrained by lap-and-shoulder restraints.

The family's wrongful death lawsuit will now be heard in the California courts where it began nearly a decade ago.

Article provided by Wood and Carlton PC
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