Williamson v. Mazda

What’s at Stake:
Protecting people who are hurt because of a car manufacturer’s negligence.

Issue:
Whether a federal regulation allowing car manufacturers to install either a lap-only or a lap-shoulder seatbelt preempts a state negligence claim based on the manufacturer’s failure to install a lap-shoulder belt. 

Decision date:
February 23, 2011

Outcome:
8-0 in favor of Williamson. Justice Breyer delivered the opinion; Justice Sotomayor filed a concurring opinion; Justice Thomas filed an opinion concurring in the judgment; Justice Kagan recused.

What the court held:
The court held 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 used a lap-and-shoulder seatbelt instead of a lap seatbelt.

Thanh Williamson was killed while riding in the second row of a Mazda minivan during a head-on collision. She died from severe abdominal injuries and internal bleeding when her body jackknifed around her lap seatbelt during the collision. Her family sued and alleged in state court that, although Mazda complied with the federal seatbelt regulation, it was negligent for installing only a lap seatbelt given the foreseeability of serious injuries and deaths to passengers protected only by lap seatbelts.

The court held that such state court claims do not conflict with the federal regulation requiring a lap-and-shoulder or a lap-only 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.” The regulation in Geier provided a choice for safety reasons, but the regulation in this case provided a choice for convenience and cost reasons while encouraging manufacturers to eventually install lap-and-shoulder belts by addressing such concerns through innovation. As a result, the state tort claim does not conflict with the federal regulation and is not preempted. 

Learn more:

• The Wall Street Journal: Supreme Court Clears Way for Seat-Belt Lawsuits
• Washington Post: Court weighs allowing Mazda seat belt lawsuit
• WTOP: Court weighs allowing Mazda seat belt lawsuit

Merit briefs:

• Brief for Petitioner Delbert Williamson, et al.
• Brief for Respondent Mazda Motor of America, Inc.
• Reply Brief for Petitioner Delbert Williamson, et al.

Amicus briefs:

• Brief for the United States of America in Support of Petitioner
• Brief for Constitutional Accountability Center in Support of Petitioner
• Brief for the States of Illinois, Arizona, Arkansas, California, Hawaii, Iowa, Kansas, Louisiana, Maryland, Minnesota, Mississippi, Montana, Nevada, New Hampshire, New Mexico, Ohio, Oklahoma, Tennessee, Utah, Vermont, West Virginia, Wisconsin, and Wyoming and the District of Columbia in Support of Petitioner
• Brief for Public Justice, P.C. in Support of Petitioner
• Brief for American Association for Justice in Support of Petitioner
• Brief for Attorneys Information Exchange Group in Support of Petitioner
• Brief for the Product Liability Advisory Council, Inc., in Support of Respondent
• Brief for the Alliance of Automobile Manufacturers, the Association of International Automobile Manufacturers, Inc., and the National Automobile Dealers Association Support of Respondent
• Brief for the Grocery Manufacturers Association, National Association of Manufacturers, American Tort Reform Association, and Lawyers for Civil Justice in Support of Respondent
• Brief for DRI—The Voice of the Defense Bar in Support of Respondent
• Brief for United States Chamber of Commerce in Support of Respondent
• Brief for Juvenile Products Manufacturers Association in Support of Respondent