WILLIAMSON v. MAZDA MOTOR OF AMERICA, INC.

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Case Basics
Docket No. 
08-1314
Petitioner 
Delbert Williamson, et al.
Respondent 
Mazda Motor of America, Inc., et al.
Decided By 
Advocates
(for the petitioners)
(Assistant to the Solicitor General, Department of Justice, for the United States as amicus curiae supporting the petitioners)
(for the respondents)
Term:
Facts of the Case 

Three members of the Williamson family were involved in a head-on collision with another vehicle. Delbert and Alexa wore lap/shoulder seatbelts and survived, while Thanh wore a lap-only seatbelt and died. Subsequently, they sued Mazda Motor of America for strict products liability, negligence, deceit, and wrongful death in a California state court. The court dismissed the claims, holding that federal law precluded a state court tort action "to the extent the theory of liability [was rooted in] the lap-only seat belt." On appeal, a California appellate court affirmed, holding that the National Highway Traffic Safety Administration ("NHTSA") regulation allowing minivan rear seats to have either lap-only or lap/shoulder seat belts preempted state court wrongful death actions.

Question 

Does the NHTSA regulation allowing vehicle manufacturers to install either lap-only or lap/shoulder seatbelts in certain seating positions impliedly preempt a state-law claim alleging that the manufacturer should have installed lap/should seatbelts in one of its seating positions?

Conclusion 
Decision: 8 votes for Williamson, 0 vote(s) against
Legal provision: Federal Motor Vehicle Safety Standard 208

No. The Supreme Court reversed the lower court decision in a unanimous opinion by Justice Stephen Breyer. The court held that the state tort lawsuit in this case is not preempted by federal auto safety standards. Justice Sonia Sotomayor filed a concurring opinion, while Justice Clarence Thomas filed an opinion concurring in the judgment. Justice Elena Kagan took no part in consideration of the case.

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WILLIAMSON v. MAZDA MOTOR OF AMERICA, INC.. The Oyez Project at IIT Chicago-Kent College of Law. 10 September 2014. <http://www.oyez.org/cases/2010-2019/2010/2010_08_1314>.
WILLIAMSON v. MAZDA MOTOR OF AMERICA, INC., The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/2010-2019/2010/2010_08_1314 (last visited September 10, 2014).
"WILLIAMSON v. MAZDA MOTOR OF AMERICA, INC.," The Oyez Project at IIT Chicago-Kent College of Law, accessed September 10, 2014, http://www.oyez.org/cases/2010-2019/2010/2010_08_1314.