(CN) – The U.S. Supreme Court on Wednesday revived a wrongful death lawsuit against Mazda Motor of America for failing to equip all vehicle seats with lap-and-shoulder belts, instead of simple lap belts.
Thanh Williamson was killed while sitting in a middle-row, aisle seat of a 1993 Mazda minivan. Her husband was driving the vehicle, and her daughter was sitting beside her in the middle row, when it was struck head-on by a Jeep Wrangler that broke free from a motor home that was towing it.
Federal safety standards for motor vehicle give auto manufacturers an option about what kind of seatbelt to install in certain inner seats in the rear or middle rows. While seats next to the doors or frames must come with lap-and-shoulder belts, the middle or aisle seats can feature simple lap belts.
Thanh’s seat came with a lap belt, while her family survived the accident, protected by shoulder-and-lap belts. The family sued Mazda, claiming that the company should have installed a combination belt on Thanh’s seat. A California state court dismissed the lawsuit, finding the claims were pre-empted by federal regulations, and the state’s fourth appellate district affirmed.
Writing for the court, Justice Stephen Breyer said certiorari was granted since several lower courts have buttressed their findings of pre-emption using the Supreme Court’s 2000 decision, Geier v. American Honda Motor, over airbag requirements. The court heard arguments on the case in November.
Though Justice Clarence Thomas wrote a separate concurring opinion Wednesday, the Supreme Court was unanimous in its decision that Williamsons’ lawsuit was not pre-empted since “providing manufacturers with this seatbelt choice is not a significant objective of the federal regulation.”
The court found in Geier that a significant objective of federal regulation was served by giving auto manufacturers a choice among different kinds of passive restraint devices, rather than favoring one type of passive restraints, such as airbags.
Unlike the significant care that went into airbag regulations, Breyer noted that the biggest concern for the Transportation Department in giving automakers a choice with regard to rear seat belts was that a lap-and-shoulder requirement would not be cost effective.
“But that fact – the fact that DOT made a negative judgment about cost effectiveness – cannot by itself show that DOT sought to forbid commonlaw tort suits in which a judge or jury might reach a different conclusion,” Breyer wrote, noting that DOT expected costs to drop with innovation.
Justice Sonia Sotomayor, who signed off on Breyer’s opinion, also authored a concurring opinion, emphasizing that Geier cannot be called upon to “justify implied pre-emption.”
Justice Thomas invoked the Safety Act’s savings clause as a “more direct route” to reach the majority’s conclusion.