Geier v. American Honda Motor Company

Brief Fact Summary.

Geier sued in tort, claiming American Honda had designed the car negligently and defectively by not providing a driver’s side airbag.

Synopsis of Rule of Law.

Where the rule of law for which petitioners contend would have stood as an obstacle to the accomplishment and execution of the important means-related federal objectives, the petitioners may not bring that claim.

Facts.

The 1984 version of a Federal Motor Vehicle Safety Standard promulgated by the Department of Transportation under the authority of the National Traffic and Motor Vehicle Safety Act of 1966 required auto manufacturers to equip some but not all of their 1987 vehicles with passive restraints airbags. It is argued that the Act preempts a state common-law tort action in which the plaintiff claims that the defendant auto manufacturer, who was in compliance with the standard, should nonetheless have equipped a 1987 automobile with airbags. Alexis Geier, while driving a 1987 Honda Accord equipped with manual shoulder and lap belts which Geier had buckled, collided with a tree and was seriously injured. Geier sued in tort, claiming American Honda had designed the car negligently and defectively by not providing a driver’s side airbag.

Issue.

Does the National Traffic and Motor Vehicle Safety Act of 1966 that require auto manufacturers to equip some but not all of their 1987 vehicles with passive restraints airbags violate the Constitution?

Held.

Petitioners have argued generally that, to be safe, a car must have an airbag. FMVSS 208 sought a gradually developing mix of alternative passive restraint devices for safety-related reasons. The rule of state tort law for which petitioners argue would stand as an obstacle to the accomplishment of that objective. And the statute foresees the application of ordinary principles of preemption in cases of actual conflict. Thus, the tort action is preempted.

Dissent.

Justice Stevens

While the presumption is important in assessing the preemptive reach of federal statutes, it becomes crucial when the preemptive effect of an administrative regulation is at issue. Unlike Congress, administrative agencies are clearly not designed to represent the interests of States, yet with relative ease they can promulgate comprehensive and detailed regulations that have broad preemption ramifications for state law. Honda has not overcome the presumption in the case. Neither Standard 208 nor its accompanying commentary includes the slightest specific indication of an intent to preempt common-law no-airbag suits.

Discussion.

Petitioners’ tort action depends upon its claim that manufacturers had a duty to install an airbag when they manufactured the 1987 Honda Accord. Such a state law, a rule of state tort law imposing such a duty, by its terms would have required manufacturers of all similar cars to install airbags rather than other passive restraint systems, such as automatic belts or passive interiors. It thereby would have presented an obstacle to the variety and mix of devices that the federal regulation sought. It would have required all manufacturers to have installed airbags in respect to the entire District of Columbia-related portion of their 1987 new car fleet. It thereby also would have stood as an obstacle to the gradual passive restraint phase-in that the federal regulation deliberately imposed. Because the rule of law for which petitioners contend would have stood as an obstacle to the accomplishment and execution of the important means-related federal objectives, it is preempted.