529 U.S. 861, 874–75 (2000)
In 1987, petitioner Alexis Geier, then four months old, was a passenger in a 1987 Honda Accord that crashed into a tree. The car was equipped with manual shoulder and lap belts but had no airbag. The lap and shoulder belt did not prevent Alexis from striking her head on the dashboard, and she suffered serious injuries as a result.1
Alexis and her parents sued the car's manufacturer, American Honda Motor Company, Inc., and its American distributor, Honda of America Manufacturing, Inc., in the United States District Court for the District of Columbia. They claimed that American Honda had designed its car negligently and defectively because it lacked a driver's side airbag. American Honda moved for summary judgment on the ground that the National Traffic and Motor Vehicle Safety Act of 1966 and FMVSS 208 preempted the lawsuit.2
The District Court dismissed the lawsuit. The Court of Appeals for the District of Columbia Circuit affirmed the dismissal. The Supreme Court granted certiorari to decide whether the Act or the safety standard preempts a no-airbag lawsuit.3
FMVSS 208, promulgated under the Act, required auto manufacturers to equip some but not all of their 1987 and later model vehicles with passive restraints. The standard required manufacturers to equip 10 percent of their 1987 vehicles, 25 percent of their 1988 vehicles, 40 percent of their 1989 vehicles, and 100 percent of their 1990 and later vehicles with one of several different passive restraint systems, including airbags, automatic safety belts, or other passive restraints providing at least the same level of crash protection.4
Whether the National Traffic and Motor Vehicle Safety Act of 1966's express pre-emption provision preempts a state common-law tort claim alleging that a 1987 vehicle was negligently and defectively designed because it lacked a driver's side airbag?5
The Act's express pre-emption provision does not preempt the claim because the agency's views indicate that it did not intend the provision to bar common-law claims.6
No. The provision's pre-emption of any state safety standard that differs from a federal standard does not apply to a state-law tort action.7 The agency's own views on the subject indicate that it did not intend the provision to bar common-law claims.8
The agency's comments accompanying its promulgation of FMVSS 208 explicitly stated that the standard does not affect the right of the injured person to recover under common law.9 This and other agency statements suggest it wanted to leave the no airbag common-law claim free to proceed.10
The Geiers' claim is a common-law tort action arising from the 1987 Honda Accord crash, not a positive enactment by the state legislature or its administrative agencies.11
The express pre-emption provision does not preempt the claim.12
Related opinions on this issue
Joined by Justice Ginsburg
Justice Stevens, joined by Justice Ginsburg, dissented on the ground that the express pre-emption provision is limited to state safety standards applicable to the same aspect of performance as a federal standard.13 A common-law tort claim is not a standard in the same sense as a statute or regulation.14 The saving clause makes this distinction clear by providing that compliance with a federal standard does not exempt a manufacturer from common-law liability.15
The Court's reliance on the agency's views is misplaced because agency interpretations cannot overcome the clear text of the statute.16
Whether ordinary pre-emption principles preempt the Geiers' no-airbag claim because it conflicts with FMVSS 208?17
Under ordinary pre-emption principles, the Act preempts the claim because it conflicts with the objectives of FMVSS 208.18
Yes. The basic question is whether the state requirement actually conflicts with the federal requirement.19 Such a conflict exists where state law stands as an obstacle to the accomplishment and execution of the full purposes and objectives of Congress.20
The Secretary has authority to set FMVSS 208's passive restraint requirements.21 The 1984 version of the standard permitted manufacturers a choice among different passive restraint devices.22 The Secretary's contemporaneous explanation of FMVSS 208 makes clear that the standard deliberately provided the manufacturer with a range of choices among different devices. This choice was intended to further significant regulatory objectives such as reducing the cost of the passive restraint requirement and increasing the likelihood that the industry would comply with it.23
The no airbag state-law claim conflicts with the objectives of FMVSS 208. It would have required the manufacturer to install an airbag in the 1987 Accord when FMVSS 208 gave it a choice of restraints. The manufacturer chose to install a manual lap and shoulder belt with a driver's side airbag.24 The 1987 Honda Accord involved in the crash lacked an airbag consistent with that choice under the phase-in schedule requiring only 10 percent of 1987 vehicles to have passive restraints.25
The claim is preempted under ordinary pre-emption principles.26
Related opinions on this issue
Joined by Justice Ginsburg
Justice Stevens, joined by Justice Ginsburg, dissented on the ground that the 1984 version of FMVSS 208 gave manufacturers a choice of passive restraints but did not prohibit manufacturers from installing airbags.27 A state-law claim that would have required an airbag in this particular vehicle does not stand as an obstacle to the accomplishment of the federal objectives.28 The federal standard was intended to provide a minimum level of safety, not to prevent states from providing additional protections through the common law.29
Whether the Act's saving clause bars the application of ordinary conflict pre-emption principles to the Geiers' claim?30
The Act's saving clause does not bar the ordinary working of conflict pre-emption principles.31
No. The clause's language provides that compliance with a federal safety standard does not exempt any person from any liability under common law. This language cannot be read to mean that compliance with a federal standard does not preempt a state-law tort action.32
The clause's history and the history of the Act's pre-emption provision indicate that Congress intended the clause to preserve state-law liability only where there is no conflict with federal law.33 The clause's language is not sufficiently clear to bar the ordinary working of pre-emption principles.34
The clause's inclusion in the Act cannot be read as an express endorsement of the petitioners' pre-emption views. The legislative history indicates that it was intended to preserve the ability of common-law claims to proceed where there is no conflict, not to prevent conflict pre-emption.35
The saving clause does not bar conflict pre-emption.36
Related opinions on this issue
Joined by Justice Ginsburg
Justice Stevens, joined by Justice Ginsburg, dissented on the ground that the saving clause explicitly preserves common-law claims and that the majority's conclusion effectively reads this clause out of the statute.37 He maintained that the text, structure, and history of the Safety Act demonstrate Congress's intent to allow state tort actions to proceed even in the face of potential conflicts with federal standards.38 Stevens argued that the saving clause was designed to prevent compliance with federal regulations from serving as a shield against common-law liability, and the Court's application of conflict pre-emption undermines this congressional purpose.39
This view diverges sharply from the majority by insisting that the saving clause limits the operation of implied pre-emption principles in this statutory scheme, thereby preserving the traditional role of state tort law in promoting vehicle safety.40