Geier v. American Honda Motor Co., 529 U.S. 861 (2000)

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certiorari to the united states court of appeals for the district of columbia circuit

No. 98-1811. Argued December 7, 1999—Decided May 22, 2000

Pursuant to its authority under the National Traffic and Motor Vehicle

Safety Act of 1966, the Department of Transportation (DOT) promulgated Federal Motor Vehicle Safety Standard (FMVSS) 208, which required auto manufacturers to equip some but not all of their 1987 vehicles with passive restraints. Petitioner Alexis Geier was injured in an accident while driving a 1987 Honda Accord that did not have such restraints. She and her parents, also petitioners, sought damages under District of Columbia tort law, claiming, inter alia, that respondents (hereinafter American Honda) were negligent in not equipping the Accord with a driver's side airbag. Ruling that their claims were expressly pre-empted by the Act, the District Court granted American Honda summary judgment. In affirming, the Court of Appeals concluded that, because petitioners' state tort claims posed an obstacle to the accomplishment of the objectives of FMVSS 208, those claims conflicted with that standard and that, under ordinary pre-emption principles, the Act consequently pre-empted the lawsuit.

Held: Petitioners' "no airbag" lawsuit conflicts with the objectives of

FMVSS 208 and is therefore pre-empted by the Act. Pp. 867-886.

(a) The Act's pre-emption provision, 15 U. S. C. 1392(d), does not expressly pre-empt this lawsuit. The presence of a saving clause, which says that "[c]ompliance with" a federal safety standard "does not exempt any person from any liability under common law," 1397(k), requires that the pre-emption provision be read narrowly to pre-empt only state statutes and regulations. The saving clause assumes that there are a significant number of common-law liability cases to save. And reading the express pre-emption provision to exclude common-law tort actions gives actual meaning to the saving clause's literal language, while leaving adequate room for state tort law to operate where, for example, federal law creates only a minimum safety standard. Pp. 867-868.

(b) However, the saving clause does not bar the ordinary working of conflict pre-emption principles. Nothing in that clause suggests an intent to save state tort actions that conflict with federal regulations. The words "[c]ompliance" and "does not exempt" sound as if they simply


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