Upcoming Supreme Court Decision Could Open Door for More Lawsuits Against Car Makers

May 19, 2011

The U.S. Supreme Court recently heard oral arguments in a case that has the potential to make it easier for accident victims and their families to bring products liability claims against automobile manufacturers. In Williamson v. Mazda Motor Corp. of America (No. 08-1314), the Court has been asked to decide whether federal safety regulations preempt state-based products liability claims against car manufacturers.

In Williamson, 32-year-old Thanh Williamson died as a result of injuries sustained in a 2002 car crash. Williamson was sitting in the second row seat of a 1993 Mazda MPV minivan at the time of the crash. The force of the crash made Williamson jackknife around the lap belt seatbelt she wore, causing internal injuries that eventually led to her death.

At the time the minivan was manufactured, federal regulations only required car manufacturers to install lap belts in rear seats. The National Highway Transportation Safety Administration (NHTSA) did not amend the regulation to require automakers to include shoulder harnesses and lap belts in the rear seats of motor vehicles until September 2007.

Williamson's husband filed a wrongful death suit against Mazda in California, arguing that the car manufacturer negligently designed the vehicle by failing to include shoulder-lap restraint systems in the rear seats. The trial court barred the claim on the basis that it was preempted by federal safety regulations. The appeals court affirmed the lower court's holding and the California Supreme Court declined to hear the case.

The decision by the California state courts to bar the claim against Mazda was based on an earlier decision by the Supreme Court in Geier v. American Honda Co. In this case, the Court held that a previous version of a federal regulation that gave auto manufacturers the option - but did not make it a requirement - to install air bags preempted state tort claims against car manufacturers based on their failure to install airbags.

Mazda Urges Court to Find in Favor of Preemption

Before the Supreme Court, Mazda's attorneys argued that the Court should uphold its earlier ruling in Geier and find that federal safety regulations preempt the Williamsons' claim against the car maker. According to Mazda, the NHTSA gave automakers the option pre-2007 whether to use lap belts or lap and shoulder belts in back seats, just like the option it gave automakers in Geier over whether to install airbags.

The Williamsons, on the other hand, argued that this case is not like Geier and that the NHTSA did not intend to give automakers a range of safety options like it did in Geier. The NHTSA also filed an amicus brief in favor of Williamson, stating that the agency did not believe its safety standards should be used as a shield for the car industry against suits alleging that they had failed to do enough to make their vehicles safe.

The NHTSA's position in this case is important - the federal agency had sided with Honda in Geier. The NHTSA said that lower courts consistently have misinterpreted Geier to find that anytime the NHTSA gives manufacturers different options to satisfy a safety standard, this means that state tort claims are preempted. The NHTSA said that federal preemption based on safety standards should be the exception rather than the rule.

Unclear How Court Will Rule

At this point, it is unclear how the Court ultimately will rule. Some commentators believe the Court will split 4-4 on the decision, which would leave the California appellate decision in favor of automakers in place. A 4-4 decision would be possible because the newest Justice, Elena Kagan, recused herself from the case; prior to her appointment to the Supreme Court, Justice Kagan served as a solicitor general and had encouraged the Court to take the case in 2009.

Others, however, believe a more probable outcome is that the holding in Geier will survive, but that the standard will be narrowed, allowing some state claims to be brought against car manufacturers. This is based in large part on the 2009 decision in Wyeth v. Levine, another preemption case in which the Court held that consumers have the right to bring lawsuits against drug manufacturers for failing to provide adequate safety warnings - despite the fact that the FDA approved the drug and its packaging information.

Should the Court find in Williamson's favor, it would be a huge victory for consumers who have been harmed in car accidents as a result of the auto industry providing the bare minimum in safety features on their vehicles - to the point where there are even seat belt defects. However, if the Court should uphold its ruling in Geier and find that federal regulations preempt lawsuits like the one filed against Mazda, then an important avenue to justice will continue to be blocked off to accident victims.

Article provided by Carman & Bevington, P.A.
Visit us at www.tampabayaccidentlawyers.com