Term: 2002
Docket: 01-706
Rex R. Sprietsma, Administrator Of The Estate Of Jeanne Sprietsma, Deceased v. Mercury Marine, A Division Of Brunswick Corporation
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01-706 SPRIETSMA v. MERCURY MARINE Ruling below: Illinois Supreme Court, 757 N.E.2d 75. QUESTION PRESENTED This case involves the same issue raised by Lewis v. Brunswick Corp., No.97-288 (October Tenn, 1997), cert. granted, 522 U.S. 978 (1997), cert. dismissed, 523 U.S. 1113 (1998): whether common law tort claims that a boat was defectively designed because it lacked a propeller guard are preempted by federal law. In Lewis, the United States submitted an amicus curiae brief stating the federal government's view that such claims are not preempted. Lewis, however, settled after oral argument, before any decision was rendered. This case presents the first meaningful opportunity for the Court to consider this preemption issue since Lewis. The question presented is: Whether the Federal Boat Safety Act of 1971, 46 U.S.C. §§ 4301-4311 (1988 & Supp. 1993), preempts state common law claims that a recreational motor boat was defectively designed because it lacked a propeller guard when: (1) the Act expressly provides that "[c]ompliance with this chapter or standards, regulations, or orders prescribed under this chapter does not relieve a person from liability at common law or under State law" (46 U.S.C. § 4311(g)); (2) the U.S. Coast Guard has never adopted any standard or regulation with respect to propeller guards; and (3) the United States has taken the position that common law no-propeller-guard claims do not conflict with or otherwise frustrate any federal statutory or regulatory purpose? CERT. GRANTED: 1/22/02
In the case of Rex R. Sprietsma, Administrator of the Estate of Jeanne Sprietsma, Deceased v. Mercury Marine, a Division of Brunswick Corporation (2002), the U.S Supreme Court ruled in favor of Rex R. Sprietsma who was suing Mercury Marine for wrongful death after his wife died from injuries sustained when she fell overboard and was struck by their boat's propeller. The court held that federal law did not preempt state common-law claims even though there were no federal regulations requiring propeller guards on motorboats at that time. This decision allowed Mr. Spritesma to proceed with his lawsuit against Mercury Marine under Illinois state law which permitted such lawsuits if it could be proven that the product was unreasonably dangerous or lacked proper warnings about potential risks.
In the dissenting opinion for the case of Rex R. Sprietsma v. Mercury Marine, Justice Clarence Thomas argued that federal law preempted state tort claims regarding boat safety equipment standards. He contended that Congress had delegated authority to the Coast Guard to establish uniform national boat safety standards and that this delegation should be interpreted as a clear intent by Congress to occupy the field of boat manufacturing and design safety regulations completely, thereby precluding any state regulation or litigation in this area. Furthermore, he suggested that allowing individual states to impose their own varying requirements through tort lawsuits would undermine these uniform national standards and disrupt interstate commerce in violation of Congressional intent.
