Geier v. American Honda Motor Co., Inc.

529 U.S. 861 (2000)

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Nature of the Case

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Facts

Standard FMVSS 208 required auto manufacturers to equip some but not all of their 1987 vehicles with passive restraints. In 1992, Geier (P), driving a 1987 Honda, collided with a tree and was seriously injured. The car was equipped with manual shoulder and lap belts, which P had buckled at the time of the accident. The car was not equipped with airbags or other passive restraints. P sued Honda (D) in the District of Columbia. P claimed that D had designed the car negligently because it lacked an airbag. The lawsuit was dismissed. The court noted that FMVSS 208 gave the manufacturers a choice as to whether to install airbags. The court concluded that since P’s lawsuit sought to establish a different safety standard, it was preempted by a provision in the Act that preempts any safety standard that was not identical to the federal standard. The Court of Appeals agreed. But, it had doubts that P’s lawsuit would establish the kind of safety standard to which the Act’s express preemption applied. Nonetheless, it held that P’s tort law claim was an obstacle to the accomplishment of FMVSS’s objectives and that under ordinary pre-emption principles, the Act preempted the lawsuit.