Geier v. American Honda Motor Co.

Geier v. American Honda Motor Company, 529 U.S. 861 (2000), was a United States Supreme Court case in which the Court held that a federal automobile safety standard pre-empted a stricter state rule. The Court held that Alexis Geier, who suffered severe injuries in a 1987 Honda Accord, could not sue Honda for failing to install a driver-side airbag—a requirement under District of Columbia tort law but not Federal law—because Federal law pre-empted the District's rule.

Background

Alexis Geier suffered severe injuries in a 1987 Honda Accord that did not possess a driver's side air-bag. Geier and her family sought damages under the District of Columbia tort law "claiming that American Honda Motor Company was negligent in not equipping the Accord with a driver's side airbag." The District Court ruled in favor of Honda finding that "Geier's claims were expressly pre-empted by the Act." and created a conflict because the safety features of the 1987 Honda Accord were in compliance with Federal Vehicle Safety Standard (FMVSS) 208, under the National Traffic and Motor Vehicle Safety Act of 1966.^[1]

Decision of the Supreme Court

Justice Stephen G. Breyer, delivered the Court's 5-4 decision which held: "[Geier's] 'no airbag' lawsuit conflicts with the objectives of FMVSS 208 and is therefore pre-empted by the Act." The dissent challenged the majority's "unprecedented use of inferences from regulatory history and commentary as a basis for implied pre-emption."

See also

• Honda Motor Company v. Oberg
• List of United States Supreme Court cases, volume 529
• Justia: Geier v. American Honda Motor Co'.' - 529 U.S. 861 (2000)

References

Further reading

• Suing the Tobacco and Lead Pigment Industries: Government Litigation as Public Health Prescription by Donald G. Gifford. Ann Arbor, University of Michigan Press, 2010. ISBN 978-0-472-11714-7