Geier v. American Honda Motor Co. case brief summary
529 U.S. 861 (2000)
CASE FACTS
Petitioner driver collided with a tree and was seriously injured. Petitioners, the driver and her parents, sued respondent car manufacturer, claiming that respondent had designed its car negligently and defectively because it lacked a driver's side airbag. The district court dismissed the suit, and the court of appeals affirmed.
DISCUSSION
Judgment affirmed; petitioners' action was preempted, since the rule of state tort law for which they argued would have stood as an obstacle to the accomplishment of a Federal Motor Vehicle Safety Standard, which sought a developing mix of alternative passive restraint devices.
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529 U.S. 861 (2000)
CASE SYNOPSIS
On writ of certiorari to
the United States Court of Appeals for the District of Columbia
Circuit, petitioners appealed from the judgment of the appellate
court, affirming the dismissal of their "no airbag" tort
suit, finding that those claims conflicted with Federal Motor Vehicle
Safety Standard 208, and that the National Traffic and Motor Vehicle
Safety Act of 1966, former 15 U.S.C.S. § 1381 et seq.,
consequently pre-empted the suit.CASE FACTS
Petitioner driver collided with a tree and was seriously injured. Petitioners, the driver and her parents, sued respondent car manufacturer, claiming that respondent had designed its car negligently and defectively because it lacked a driver's side airbag. The district court dismissed the suit, and the court of appeals affirmed.
DISCUSSION
- The court granted certiorari and affirmed the dismissal.
- The court found that the National Traffic and Motor Vehicle Safety Act of 1966, former 15 U.S.C.S. § 1381 et seq., express preemption provision did not preempt the common-law "no airbag" action because the language permitted a narrow reading that excluded common-law actions.
- However, the court found that petitioners' suit conflicted with Federal Motor Vehicle Safety Standard (FMVSS) 208. FMVSS 208 sought a gradually developing mix of alternative passive restraint devices for safety-related reasons.
- The rule of state tort law for which petitioners argued would have stood as an obstacle to the accomplishment of that objective, and the statute foresaw the application of ordinary principles of preemption in cases of actual conflict.
- Hence, petitioners' action was pre-empted.
Judgment affirmed; petitioners' action was preempted, since the rule of state tort law for which they argued would have stood as an obstacle to the accomplishment of a Federal Motor Vehicle Safety Standard, which sought a developing mix of alternative passive restraint devices.
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