Facts
- Alexis Geier was injured in a 1992 crash while driving a 1987 Honda Accord.
- The vehicle had manual lap and shoulder belts, which Geier was wearing, but lacked an airbag or other passive restraint.
- Geier and her parents sued the manufacturer under District of Columbia tort law, alleging negligent and defective design for failure to include a driver-side airbag.
- The governing federal scheme was the National Traffic and Motor Vehicle Safety Act of 1966 and Federal Motor Vehicle Safety Standard (FMVSS) 208 (1984 version).
- FMVSS 208 required passive restraints in some, but not all, 1987 model-year vehicles and allowed manufacturers a choice among different passive-restraint technologies.
Issues
- Whether the Safety Act’s express preemption clause expressly preempted a state common-law tort claim based on failure to install airbags.
- Whether the Safety Act’s savings clause prevents application of implied (conflict) preemption to state tort claims.
- Whether a “no airbag” tort claim conflicts with FMVSS 208’s objectives and is therefore preempted as an obstacle to federal purposes.
Decision
- The Supreme Court affirmed the judgment for the manufacturer (5–4, Breyer, J.).
- The Court held the Safety Act did not expressly preempt the lawsuit.
- The Court held the savings clause did not foreclose implied conflict preemption.
- The Court held this particular tort claim was conflict-preempted because it would obstruct FMVSS 208’s objectives of manufacturer choice, mixed restraint technologies, and phased implementation rather than a universal airbag requirement for 1987 vehicles.
Legal Principles
- An express preemption clause, even when paired with a savings clause preserving common-law liability, does not categorically bar implied conflict preemption.
- The savings clause prevents treating federal compliance as automatic immunity from tort liability, but it does not preserve state claims that conflict with federal regulatory objectives.
- State law is preempted when it stands as an obstacle to accomplishing the full purposes and objectives of federal law, including agency regulations implementing a statutory scheme.
- When a federal safety standard deliberately permits a range of compliance options to advance a regulatory plan, a state tort rule that effectively eliminates those options can be conflict-preempted.
Conclusion
The Court held that although the Safety Act’s express preemption provision did not itself bar the common-law claim, the claim was impliedly preempted because imposing tort liability for failure to install an airbag in a 1987 vehicle would undermine FMVSS 208’s federally chosen strategy of a gradual, mixed-technology introduction of passive restraints.