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Doomes v. Best Transit Corp.

New York Court of Appeals
958 N.E.2d 1183 (2011)

Facts

A bus carrying 21 passengers hit an embankment and rolled several times after its driver dozed off. Several passengers were injured, including Gloria Doomes (plaintiff). Doomes and the other injured passengers (collectively plaintiffs) filed suit against a number of companies, including the manufacturer of the bus, Warrick Industries, Inc. (Warrick) (defendant) and the operator of the bus, Best Transit Corporation (defendant). In their complaint, Plaintiffs alleged that the lack of seatbelts for the passengers caused their injuries. Warrick filed a motion to preclude any evidence that the bus was defective due to a lack of passenger seatbelts. In support of its motion, Warrick claimed that the Federal Motor Vehicle Safety Standard (FMVSS) 208, as part of the National Traffic and Motor Vehicle Safety Act, preempted any state claims. The trial court declined to rule on Warrick’s motion. The jury found Warrick liable and awarded damages to Plaintiffs. Warrick appealed. The appellate division reversed and held that Plaintiffs’ passenger seatbelt claims were preempted by federal law. Plaintiffs appealed. The New York Court of Appeals granted certiorari to review.

Rule of Law

Issue

Holding and Reasoning (Jones, J.)

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