Geier v. American Honda Motor Co., 529 U.S. 861; 98-1811 (2000)
- Category: Personal injury; preemption
- Holding: 5-4 for the respondent/defendant.
- 529 U.S. 861; 98-1811
Alexer Geier was involved in a serious car accident in the District of Columbia in 1987. He suffered numerous and significant injuries across his body. Part of the reason he did incur these wounds, in his opinion, was because there was no driver’s side airbag in his car: a Honda Accord. What was the rule at that time? Well, federal law mandated that car makers equip their vehicles at least with passive restraints so Honda put in seat belts and warning lights in its Accords (See the Federal Motor Vehicle Safety Standard 208 that was promulgated by the Department of Transportation pursuant to the National Traffic and Motor Vehicle Safety Act). However, the District of Columbia had its own rule-it required driver’s side airbag. Therefore, he sued according to the latter standard and sought damages from Honda arguing that “American Honda Motor Company was negligent in not equipping the Accord with a driver’s side airbag.” The District Court disagreed. It ruled that federal law preempted Geier’s claims and the Appellate Court affirmed that decision. Undeterred, he appealed to the Supreme Court and was granted certiorari.
Is the petitioner’s tort case preempted by federal law (National Traffic and Motor Safety Act of 1966) when the defendant complied with federal law but not state-sanctioned mandates?
A thorough understanding of this case requires an analysis of preemption. Federal preemption is the legal theory that state laws are invalidated if they conflict with federal laws. Why is this the case? It starts with the Supremacy Claude of the United States Constitution:
“This Constitution, and the laws of the United States which shall be made in pursuance thereof; and all treaties made, or which shall be made, under the authority of the United States, shall be the supreme law of the land; and the judges in every state shall be bound thereby, anything in the Constitution or laws of any State to the contrary notwithstanding.” Article VI, clause 2
As the Court declared in Altria Group v. Good, if state and federal laws run head on into each other, then the federal law trumps the state law and is to be followed. 555 U.S. 70 (2008). However, another touchstone of the law is that strong deference is given to state powers. Therefore, unless there is an explicit sign from Congress of its intent to supersede state law, courts should not presume preemption as the Court held in Medtronic, Inc. v. Lohr: “we start with the assumption that the historic police powers of the States were not to be superseded by the Federal Act unless that was the clear and manifest purpose of Congress.” 518 U. S. 470, 485 (1996). Thus, this explains why states and the federal government contain some concurrent powers. Here, the Court then had to analyze whether the state and federal law actually were in conflict; whether this was meant to be a concurrent power or at least a dimension where the states were supposed to maintain some amount of deference; or whether the state law thwarted the purpose and spirit of the federal law.
The Court found that the airbag demand and subsequent lawsuit directly conflicted with federal law and the goal of the regulations passed thereunder (Federal Motor Vehicle Safety Standard 208). The federal aim was to allow car makers to use a combination of safety devices and did not specifically name airbags where the law cited in the present case solely demanded airbags. This would thwart Congressional intent and thus is preempted according to the Supreme Court. Therefore, the Court affirmed the lower court’s ruling and left the plaintiff/petitioner with little recourse to pursue recovery.
Yes, the petitioner’s tort case is preempted by federal law (National Traffic and Motor Safety Act of 1966) when the defendant complied with federal law but not state-sanctioned mandates that directly conflicted with Congressional intent.
There were five justices for the majority (Breyer, Rehnquist, O’Connor, Scalia, and Kennedy) and four justices for the minority (Stevens, Souter, Thomas, and Ginsburg).
The immediate effect of this decision was that the person injured in the car crash could not receive the compensation that he deserved. However, the Supreme Court did not render its opinion until nearly a decade and a half after the underlying incident so the plaintiff probably could have predicted this early on into the proceedings. What is more important to gather here, however, were the fault lines that the Court threw down between state and federal laws. As the Court ruled in this case, the federal law is supreme and attempts to encroach upon that terrain will be summarily dispatched. Airbags were just one example but others might surface in the legal system and this rule will be the guide to determine the outcome.