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Delbert Williamson v. Mazda Motor of America, Inc.

On August 6, 2010, CAC filed an amicus brief in the U.S. Supreme Court in Williamson v. Mazda Motor, an important case concerning the ability of consumers to hold motor vehicle manufacturers liable for safety defects.

The case involved a tragic car accident: the Williamsons were riding in their 1993 Mazda minivan when it was struck by another vehicle; according to the lawsuit filed by the Williamson family, Mrs. Williamson died as a result of the internal injuries she suffered when her body jackknifed over the lap-only seatbelt she was wearing in the rear seat of the minivan. The Williamsons sought to hold Mazda responsible for this lap-only seatbelt arrangement, and brought a common-law tort claim in California court arguing that Mazda should have installed a lap/shoulder belt. Although the federal motor vehicle safety standard did not require car manufacturers to install lap/shoulder belts in the vehicle location in which Mrs. Williamson was seated, this federal standard established only a regulatory floor, not a ceiling. Mazda was not precluded from meeting the higher state safety standard, and, indeed, through jury verdicts and traditional state common-law remedies, states may hold manufacturers to a higher standard of safety than the federal government does.

Williamson required the Supreme Court to revisit the doctrine of “implied preemption,” last applied by the Court in Wyeth v. Levine (in which CAC also filed a brief). Under the implied preemption doctrine, a court may hold that a state law is preempted by a federal law, even though the federal statute does not expressly provide for preemption. CAC’s brief, which supported the vitality of state common-law remedies that enhance Americans’ safety, argued that the text and history of the Constitution’s Supremacy Clause – which makes federal law controlling over state and local laws – does not support broad implied preemption of state laws and remedies and only requires preemption when a state law or remedy directly conflicts with federal law. Establishing the supremacy of federal laws when an actual conflict arises between state and federal law is necessary and important to the functioning of our federal government. But so, too, is the vital and historical role that state common law plays in protecting the public’s health and safety and in ensuring that individuals can obtain compensation for injuries caused by the failure of corporations or persons to meet a state’s health and safety standards.

On February 23, 2011, the Supreme Court ruled unanimously in favor of the Williamsons, upholding their right to sue Mazda in state court and continuing a recent trend by the Court to reject preemption claims premised on the assertion that the state law represents an “obstacle” to the objectives of federal law. CAC’s argument that the entire doctrine of “obstacle” preemption is inconsistent with the federal/state balance established by the Constitution was adopted by Justice Clarence Thomas in his concurring opinion.

CAC’s statement on the Court’s ruling in Williamson can be found here, and our analysis of the ruling is here.