The Supreme Court held today in Williamson v. Mazda that a federal regulation requiring car manufacturers to install either lap-only seatbelts or lap-and-shoulder seatbelts does not preempt state tort suits claiming that the manufacturer should have chosen a lap-and-shoulder seatbelt. Thanh Williamson’s family sued Mazda in state court after she died from severe abdominal injuries and internal bleeding in a car accident when her body jackknifed around her lap seatbelt.
The court distinguished this case from a 2000 decision – Geier v. Honda – which held that a regulation requiring manufacturers to use either airbags or passive restraints was found to preempt claims for failure to use airbags. Justice Stephen Breyer’s opinion states that the choice in Geier, unlike the choice given to manufacturers in this case, was given in order to further “significant regulatory objectives.” In addition, the solicitor general opposed preemption in this case but supported it in Geier. As a result, the court held that the state tort claim does not conflict with the federal regulation and is not preempted.