Litigation Advisory – Motor Vehicle Preemption – Williamson v. Mazda Motor of America, Inc., No. 08-1314 (Feb. 23, 2011)

By Lawrence S. EbnerFebruary 24, 2011

Supreme Court Demonstrates Again That Its Product Liability Preemption Jurisprudence is Unpredictable

Only one day after issuing a split decision in Bruesewitz v. Wyeth LLC, No. 09-152 (Feb. 22, 2011), holding that a federal vaccine injury compensation statute expressly preempts common-law damages suits for defectively designed vaccines, the Supreme Court has unanimously held in Williamson v. Mazda Motor of America, Inc., No. 08-1314 (Feb. 23, 2011), that a federal motor vehicle safety statute and DOT safety
standard do not either expressly or impliedly preempt a common-law damages suit against an automobile manufacturer for failing to install rear-seat lap-and-shoulder safety belts. The Williamson opinion (click here) goes to great lengths to distinguish the Court’s earlier, frequently cited holding in Geier v. American Honda Motor Co., 529 U.S. 861 (2000) (holding that the same federal automobile safety statute and an earlier version of the same DOT safety standard do impliedly preempt common-law damages suits based on a manufacturer’s failure to install airbags). Williamson demonstrates yet again that the Supreme Court’s product liability preemption jurisprudence is highly nuanced, and that any one decision in this chronically turbulent area of law cannot reliably predict the outcome of another.

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