U.S. Supreme Court

Case Status


Docket Number


2010 Term

Oral Argument Date

November 03, 2010

Lower Court Opinion


Questions Presented

Where Congress has provided that compliance with a federal motor vehicle safety standard does not exempt a person from liability at common law, 49 U.S.C. § 30103(e), does a federal minimum safety standard allowing vehicle manufacturers to install either lap-only or lap/shoulder seatbelts in certain seating positions impliedly preempt a state common-law claim alleging that the manufacturer should have installed a lap/shoulder belt in one of those seating positions?

Case Updates

Supreme Court rules on federal preemption of design defect claims

February 23, 2011

The Supreme Court held that federal regulation FMVSS 208 does not preempt state tort suits claiming that manufacturers should have installed lap-and-shoulder belts instead of lap belts.

U.S. Chamber files amicus brief

September 28, 2010

NCLC urged the Supreme Court to dismiss product liability claims brought against Mazda. The plaintiffs allege that a passenger died because only a lap seatbelt was installed in a minivan's seat. NCLC argued that, under the principles of implied preemption law applied in Geier v. American Honda Motor Co. the claims are preempted because the lap belt complied with standards set by the National Highway Safety Transportation Administration. NCLC warned that unsettling the principles of federal preemption would subject businesses to a patchwork of regulations that could impose an enormous burden on employers already facing a difficult economic climate.

Case Documents