On Feb. 23, the U.S. Supreme Court issued its decision in Williamson v. Mazda Motor of America Inc.1 overturning a California intermediate appellate court ruling that held automotive products liability claims involving rear compartment lap belt restraints were preempted by federal law. In rejecting federal preemption of a suit that claimed a Mazda minivan should have had rear aisle seat lap-and-shoulder belts instead of lap belts, the Court distinguished its decision 11 years earlier, in Geier v. American Honda Motor Co.,2 that a “no air bag” products liability claim attacking the manufacturer’s provision of front seat belts was preempted. Geier remains good law. It forbids courts from adjudicating certain types of restraint claims. And Williamson now holds that certain types of automotive restraint claims are permissible. So how are courts, counsel and litigants to gauge what is allowed and what is not? The answer is in the details.
Further, how, if at all, does Williamson affect implied preemption of automotive design claims attacking other crash protection or crash avoidance features of vehicles that comply with Federal Motor Vehicle Safety Standards (FMVSS)? For example, days after the Williamson decision, the Supreme Court issued a so-called “GVR” order in a case called Priester v. Ford Motor Co.,3 granting a plaintiff’s petition for certiorari, vacating the judgment upheld by South Carolina courts that threw out plaintiff’s claim as preempted and remanding the case to the Supreme Court of South Carolina “for further consideration in light of Williamson v. Mazda….”
