Fasten Your Seatbelt: U.S. Supreme Court Rules Federal Seatbelt Regulation Does Not Preempt State Law Tort Suit

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Yesterday the U.S. Supreme Court held in Williamson v. Mazda Motor of America, Inc., 562 U.S. __ (2011), that federal regulations do not preempt a claim for design defect based on the failure to provide lap-and-shoulder belts for all rear seats in a passenger vehicle. The opinion, delivered by Justice Breyer, effectively crafted a case-by-case test for determining whether federal regulations offering finite options to manufacturers preempt state law tort claims. The Court strained to distinguish a nearly identical case and significantly raised the standard for a finding of preemption under a federal regulatory scheme. Seven justices joined the majority opinion, with Justice Sotomayor concurring (Justice Kagan took no part).

In 2002, Thanh Williamson was involved in a head-on collision while riding in a Mazda minivan. She was seated in the rear of the vehicle wearing only a lap belt, and died in the accident. Two other rear-seat passengers were wearing lap-and-shoulder belts and survived. Her heirs sued Mazda in California state court, claiming that Mazda should have installed lap-and-shoulder belts on all rear seats, and that she died because her seat was only equipped with a lap belt.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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