U.S. Supreme Court

Tort Suits Citing Car Lap Belts Not Pre-empted by Federal Regs, Supreme Court Rules


The family of a woman who died while wearing a lap-only seat belt may sue Mazda for damages, even though federal regulations allowed the lap belt, the U.S. Supreme Court has ruled.

Justice Stephen G. Breyer wrote the unanimous opinion (PDF) for the court finding no federal pre-emption. There were two concurrences but no dissents. Justice Elena Kagan did not participate.

Coverage of oral arguments in the case, Williamson v. Mazda Motor of America, had raised the prospect of a 4-4 deadlock.

The suit was brought on behalf of Thanh Williamson, who died in a 2002 accident while wearing a lap belt. Federal regulations give automakers a choice between lap belts and shoulder belts for rear inner seats, including rear seats next to an aisle. But choice was not a significant objective of the regulation, Breyer wrote. As a result, there is no pre-emption barring the tort suit.

There is some evidence that the U.S. Department of Transportation didn’t require shoulder belts because of concern about “entry and exit problems” in back seats, according to the opinion.

“The more important reason why DOT did not require lap-and-shoulder belts for rear inner seats was that it thought that this requirement would not be cost-effective,” Breyer wrote. “But that fact—the fact that DOT made a negative judgment about cost effectiveness—cannot by itself show that DOT sought to forbid common law tort suits in which a judge or jury might reach a different conclusion.”

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