Geier v. American Honda Motor Co.

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529 U.S. 861 (2000), argued 7 December 1999, decided 22 May 2000, by vote of 5 to 4; Breyer for the Court, Stevens in dissent. The doctrine of implied preemption dictates that federal law overrides state law when state law is in conflict with federal law, as when state law obstructs the accomplishment of the objectives of federal law. The Court determined in Geier that state tort claims against an auto manufacturer posed an obstacle to the achievement of the safety objectives of a federal statute and federal regulations. State-law tort actions were therefore preempted.

Plaintiff brought state tort claims against defendant American Honda Motor for injuries she received in a car crash allegedly because her Honda automobile lacked an airbag passive restraint device. The auto was manufactured when federal regulations did not require the installation of an airbag but instead allowed manufacturers a number of passive restraint options. The Court, in preempting the state tort claims, opined that a state tort damage award would effectively set a mandatory airbag standard that would obstruct the objective of the federal regulations, which was to achieve safety through a phasing-in of passive restraint devices.

The Court indicated that even if the federal statute contained a provision that expressly preempted some state law but failed to demonstrate congressional intent to preempt state tort law, ordinary preemption principles still applied to impliedly preempt state tort law in an appropriate case, as when state law conflicted with or posed an obstacle to federal law. A court could even imply preemption when the federal statute contained a clause that appeared to save common-law claims from override. The decision put in question the survival of state tort claims in the face of numerous federal statutes that regulate safety, traditionally an area of state tort law concern.

Susan Raeker-Jordan

Subjects: Law.

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