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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.

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