Geier v. American Honda Motor Co.
United States Supreme Court
529 U.S. 861 (2000)
In 1966, the Department of Transportation issued the Federal Motor Vehicle Safety Standard (FMVSS 208) under the authority of the National Traffic and Motor Vehicle Safety Act. The standard required auto manufacturers to equip some but not all of their 1987 vehicles with passive restraints. In 1992, Alexis Grier (plaintiff), driving a 1987 Honda Accord manufactured by American Honda Motor Co. (Honda) (defendant), collided with a tree and was seriously injured. Her car was equipped with manual shoulder and lap belts, but no airbags or other passive restraint devices. Geier brought a state common law tort action against Honda arguing that although it was in compliance with the FMVSS 208 standard, it should still be held liable for not equipping its 1987 automobile with airbags. FMVSS 208 contained an express preemption provision indicating it could not be superseded by any state court laws to the contrary. The lower court held Geier’s lawsuit was preempted by the federal standard and the corresponding federal act. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (Breyer, J.)
Dissent (Stevens, J.)
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