## Facts

- A bus carrying about 21 passengers returned from a prison visit and traveled about 60 mph on the New York State Thruway.
- The driver fell asleep, the bus left its lane, struck the median and an embankment, and rolled over multiple times, injuring passengers.
- The bus had a seatbelt for the driver but no passenger restraints.
- Injured passengers sued, asserting (1) a design/manufacturing defect for failure to provide passenger seatbelts and (2) negligent modification/finishing that allegedly altered weight distribution and affected handling, contributing to rollover.
- The bus was completed/finished by the coach builder after a chassis/cab manufacturer supplied the underlying platform.

## Issues

1. Whether federal motor vehicle safety regulation (including FMVSS 208 under the National Traffic and Motor Vehicle Safety Act) preempts state common-law claims alleging a defect based on failure to install passenger seatbelts on a large bus.
2. Whether legally sufficient evidence supported the claim that the coach builder’s modifications negligently altered weight distribution/handling and proximately caused the crash.

## Decision

- The court held the passenger seatbelt claims were not preempted by federal law and could proceed.
- The court held the weight-distribution/handling theory lacked legally sufficient evidence and could not support liability.
- The court reversed the intermediate appellate ruling insofar as it had dismissed the seatbelt claims, while affirming dismissal of the weight-distribution theory, and remitted for further proceedings consistent with these rulings.

## Legal Principles

- The Motor Vehicle Safety Act’s saving clause preserves state common-law liability notwithstanding compliance with federal safety standards, absent a clear conflict with federal objectives.
- FMVSS 208’s lack of a requirement for passenger seatbelts on certain large buses does not, by itself, reflect an affirmative federal policy against passenger belts or impliedly bar state tort duties.
- Conflict (obstacle) preemption requires a demonstrated federal objective that would be frustrated by the state-law claim; regulatory silence or a minimum federal “floor” is generally insufficient.
- A products-liability verdict must rest on non-speculative proof of defect and causation; expert testimony must connect the alleged engineering change to the accident with more than conjecture.

## Conclusion

The court permitted state-law claims that a bus was defectively sold without passenger seatbelts because federal standards did not clearly foreclose additional safety duties, but it rejected a separate design/finishing theory where plaintiffs failed to present legally sufficient evidence that weight-distribution changes caused the rollover.


Doomes v. Best Tr. Corp., 17 N.Y.3d 594 (N.Y. 2011)