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08-1314 WILLIAMSON V. MAZDA MOTOR OF AMERICA DECISION BELOW: 84 Cal. Rptr. 3d 545 LIMITED TO QUESTION 1 PRESENTED BY THE PETITION. JUSTICE KAGAN TOOK NO PART CERT. GRANTED 5/24/2010 QUESTION PRESENTED: 1. Where Congress has provided that compliance with a federal motor vehicle safety standard does not exempt a person from liability at common law, 49 U.S.C. § 30103(e), does a federal minimum safety standard allowing vehicle manufacturers to install either lap-only or lap/shoulder seatbelts in certain seating positions impliedly preempt a state common-law claim alleging that the manufacturer should have installed a lap/shoulder belt in one of those seating positions? 2. Under this Court's recent ruling in Wyeth v. Levine, _ S. Ct. _, 2009 WL 529172 (2009), does a federal motor vehicle safety standard allowing vehicle manufacturers to install either lap-only or lap/shoulder seatbelts impliedly preempt a state tort suit alleging that the manufacturer should have warned consumers of the known dangers of a lap-only seatbelt installed in one of its vehicles? LOWER COURT CASE NUMBER: G038845
In the case of Delbert Williamson, et al. v. Mazda Motor of America, Inc., et al., 2010, the U.S Supreme Court ruled in favor of Mazda. The case was brought by the family of Thanh Williamson who died in a car accident while wearing a lap belt in the middle rear seat as per federal regulations at that time (1989). The Williamsons argued that Mazda should have installed lap-and-shoulder belts and their failure to do so made them liable for her death under state tort law. However, Mazda countered this argument stating they were following federal safety standards which allowed either type of belt to be installed during manufacturing. The court held that compliance with federal motor vehicle safety standards does not necessarily exempt auto manufacturers from liability under state common law tort actions if those manufacturers could have opted for safer but more expensive equipment options permitted by Federal Law. But it also stated that preemption did not apply here because there was no significant objective conflict between federal regulation and state law since automakers had choices about seatbelt types.
In the dissenting opinion for Williamson v. Mazda Motor of America, Justice Thomas argued that federal regulations should preempt state tort law claims. He contended that a vehicle manufacturer's decision to install lap-only seatbelts in some rear seats was made under a standard set by the Federal Motor Vehicle Safety Standard (FMVSS) 208, which allowed manufacturers to choose between installing lap-only or shoulder-and-lap belts. Therefore, he believed it was inappropriate for states to penalize manufacturers for making choices explicitly permitted by federal regulation. In his view, allowing such lawsuits would undermine uniformity and could discourage automakers from offering optional safety equipment not required by federal standards out of fear they might be sued if they do not make those options standard on all vehicles.