Monday, March 25, 2013

Freightliner Corp. v. Myrick case brief

Freightliner Corp. v. Myrick case brief
514 U.S. 280 (1995)

Petitioner tractor-trailer manufacturers sought review of a judgment of the United States Court of Appeals for the Eleventh Circuit in respondent accident victims' consolidated actions, seeking damages for personal injuries sustained in collisions caused by defective equipment. Petitioners urged that the appellate court erred in reversing summary judgment in their favor on the grounds of no preemption of the state law claims.

OVERVIEW: Respondent accident victims filed negligent design actions against petitioner tractor-trailer manufacturers, seeking to recover damages for personal injuries they sustained in vehicle collisions allegedly caused by the absence of antilock braking systems (ABS) on trucks that petitioners manufactured. The appellate court consolidated the actions and reversed the grant of summary judgment to petitioners, ruling that respondents' state law claims were not preempted by the National Traffic and Motor Vehicle Safety Act (Act), 15 U.S.C.S. § 1381 et seq. Petitioners sought a writ of certiorari, claiming express and implied preemption.

The court affirmed, ruling that the preemption argument failed because respondents' common-law actions did not conflict with federal law.

It was not impossible for petitioners to comply with both federal and state law because there was no federal standard for a private party to satisfy. Nothing in the Act or its regulations regulated the use of ABS devices. A prior suspended standard imposed no requirements either requiring or prohibiting ABS systems. The absence of a federal standard could not implicitly extinguish state common law.

OUTCOME: The court affirmed the judgment of the appellate court that reversed the award of summary judgment for petitioner tractor-trailer manufacturers in respondent accident victims' consolidated actions for design negligence. A suspended federal standard did not expressly preempt state law claims, and the absence of a federal standard could not impliedly extinguish state common law.

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