Late last month, the United States Supreme Court held in Williamson v. Mazda Motor of America, Inc., that federal regulations allowing for lap restraints in minivan-style vehicles did not preempt California state law. This unanimous decision has since allowed for the injured plaintiff in the case to proceed in California state court in its wrongful death action against the automaker. This decision holds many positive ramifications for California plaintiffs injured by automobile defects. Plaintiffs once frustrated by an apparent federal preemption may now seek restitution for injuries sustained as a result of lap seatbelt manufacturing defects in a minivan.
In 2002, while riding in the rear-middle seat of the family’s 1993 Mazda minivan, Thanh Williamson suffered severe internal bleeding and died as a result of injuries sustained after the minivan collided with a Jeep. Her body was thrown into a “jackknife” position around the lap seatbelt. Williamson’s family members, also passengers in the minivan, were wearing lap and shoulder seatbelts and both survived the collision. Williamson’s estate immediately brought a wrongful death action against the auto-maker, claiming it was negligent in installing lap seatbelts in the rear seats as opposed to lap and shoulder seatbelts.
Williamson’s wrongful death action was met with opposition and quickly dismissed by two California state courts. Both courts held that the plaintiff was preempted from suing in state court due to the fact that in 1989 Congress enacted seatbelt regulations which allowed for lap seatbelts in the rear-middle seats of a minivan. The courts reasoned that since Mazda’s lap seatbelt design was expressly prescribed by the federal statute, the plaintiff could not sue Mazda under any theory of negligence and prevail.
Williamson’s writ of certiorari to the United States Supreme Court was granted and the Court unanimously held otherwise. In an opinion written by Justice Breyer, the Court struck down Mazda’s argument for immunity from liability and held the federal regulations with regard to minivan seatbelt design do not shield automakers from liability for choosing to install the lap seatbelts. In other words, simply because the lap seatbelts are not prohibited by the federal government, they are by no means necessarily immune from liability.
How will this holding impact California’s auto-injury plaintiffs? The Court’s decision in Mazda has paved the way for plaintiffs injured by lap seatbelts to pursue their claims in California state court and to argue for restitution and damages stemming from their injuries. These expanded opportunities for restitution against automakers will hopefully lead to safer seatbelt design and an overall awareness that compliance with federal regulation does not necessarily amount to immunity from liability.
Automakers should gain from this holding that federal compliance is no shield to liability. Federal regulations are often bare-bones minimum standards and do not purport to set a reasonable standard of care in the auto-making industry. Thus, it is imperative for the automotive industry to implement vehicle designs which adhere to the strictest standards of safety, as opposed to the minimum standards allowable to avoid federal admonishment.
In a concurring opinion written by Justice Thomas, he astutely opined that the majority was making the decision entirely too complicated as Congress expressly included in the regulatory statute that its regulations did not serve to preempt any liability of the auto manufacturer.
The holding in Mazda will hopefully open the door for any injured plaintiff to seek the restitution and damages he or she deserves as the automotive industry can no longer hide behind federal preemption to avoid liability for negligent lap seatbelt design.
