Geier v. American Honda Motor Company

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Geier v. American Honda Motor Company
Seal of the United States Supreme Court.svg
Argued December 7, 1999
Decided May 22, 2000
Full case name Alexis Geier, et al., petitioners v. American Honda Motor Company, Inc., et al.
Citations 529 U.S. 861 (more)
120 S. Ct. 1913; 146 L. Ed. 2d 914; 2000 U.S. LEXIS 3425; 68 U.S.L.W. 4425; CCH Prod. Liab. Rep. P15,795; 2000 Cal. Daily Op. Service 5277; 2000 Daily Journal DAR 5277; 2000 Colo. J. C.A.R. 2826; 13 Fla. L. Weekly Fed. S 344
Prior history dismissed (D.D.C. 1997), affirmed 166 F.3d 1236 (D.C.C.A. 1999), affirmed 529 U.S. 861 (2000)
Holding
The Federal standards for motor vehicle pre-empts tort lawsuits made under stricter state legislations.
Court membership
Case opinions
Majority Breyer, joined by Rehnquist, O'Connor, Scalia, and Kennedy
Dissent Stevens, joined by Souter, Thomas, Ginsburg
Laws applied
National Traffic and Motor Vehicle Safety Act

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[edit]

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 Colombia 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[edit]

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[edit]

References[edit]

  1. ^ "Geier v. American Honda Motor Co. - 529 U.S. 861 (2000)". Oyez: Chicago-Kent College of Law. Retrieved 1 December 2013. 

Further reading[edit]