Wednesday, February 23, 2011
Supreme Court Rejects Preemption Defense, 8-0, in Product Defects Case
Good news today from the U.S. Supreme Court.
In a decision issued this morning inWilliamson v. Mazda, the Court unanimously held that state-law damages claims seeking to hold an automaker accountable for its vehicle-design choices were not barred by federal regulation of motor vehicles. Justice Breyer wrote the opinion for the Court, which was joined by the Chief and Justices Scalia, Kennedy, Ginsburg, Alito, and Sotomayor; Justice Sotomayor wrote a concurring opinion and Justice Thomas concurred only in the judgment. (Justice Kagan was recused.) Justice Thomas's short concurrence is a particularly interesting read for those interested in the development of preemption doctrine. Building on his pathbreaking opinions in Wyeth v. Levineand other recent preemption cases, Justice Thomas takes the position that the plain text of the savings clause in the relevant statute (the Safety Act) should have governed the case, thus obviating the need to engage in any consideration of so-called purposes-and-objectives preemption. Justice Thomas's distinctive, textualist jurisprudence in this area may tip the balance in other preemption cases pending this term, including perhaps AT&T Mobility v. Concepcion.
Thanh Williamson was killed while riding in the second-row aisle seat of a Mazda minivan when it was struck head on by another vehicle. Her seat was equipped with a lap-only seatbelt, which caused fatal internal injuries when the impact of the collision caused her body to jackknife over the belt. After her death, Mrs. Williamson’s family brought suit against Mazda, alleging that the van was defective because it lacked a lap/shoulder belt for the aisle seat. When the minivan was manufactured and sold, the relevant federal safety standard allowed but did not require that seat to have a lap/shoulder belt.
The question before the Court was whether the Williamsons’ damages claims were barred by implied conflict preemption, on the theory that holding Mazda accountable for failing to install a lap/shoulder belt would pose an obstacle to the federal safety standard in effect at the time. In a unanimous decision, the Court held that the claims were not preempted. The case will now return to the trial court, where the Williamsons will have an opportunity to litigate their case on the merits.
The question before the Court was whether the Williamsons’ damages claims were barred by implied conflict preemption, on the theory that holding Mazda accountable for failing to install a lap/shoulder belt would pose an obstacle to the federal safety standard in effect at the time. In a unanimous decision, the Court held that the claims were not preempted. The case will now return to the trial court, where the Williamsons will have an opportunity to litigate their case on the merits.
One of my colleagues here at Public Citizen Litigation Group, Allison Zieve, helped to secure this important victory in the fight against broad theories of preemption, which are used to deny consumers access to the civil justice system. The Williamsons’ lead counsel in the Supreme Court was Martin Buchanan of San Diego. As co-counsel in the Supreme Court, Allison worked closely with Martin on briefing and argument preparation. Congratulations to Martin on such a resounding victory in his first appearance before the U.S. Supreme Court!
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