Geier v. American Honda Motor Co.
Citation: 529 U.S. 861 (2000) Court: Supreme Court of the United States
Facts
Alexis Geier was seriously injured in a 1987 automobile accident when her Honda Accord — which lacked an airbag — struck a tree. She sued American Honda Motor Co. under D.C. common law, alleging the car was negligently designed because it lacked a driver’s side airbag. Honda asserted that Federal Motor Vehicle Safety Standard (FMVSS) 208, issued under the National Traffic and Motor Vehicle Safety Act, preempted her tort claim. FMVSS 208 deliberately gave manufacturers a choice among several passive restraint systems rather than mandating airbags specifically.
Issue
Whether a state tort law claim requiring manufacturers to install airbags is preempted by a federal safety standard that gave manufacturers discretion to choose among multiple passive restraint options.
Holding
The Supreme Court (5-4) held that Geier’s common law tort claim was preempted by FMVSS 208 under the doctrine of obstacle preemption (a form of conflict preemption). A state rule requiring airbags would have stood as an obstacle to the federal standard’s deliberate policy of allowing manufacturer choice.
Rule / Doctrine
Obstacle preemption: state law is preempted when it stands as an obstacle to the accomplishment of the full purposes and objectives of Congress (and here, the agency acting pursuant to congressional authority). Even if compliance with both federal and state law is technically possible, a state rule that contradicts the purposes and design of a federal regulatory scheme is impliedly preempted. The deliberate federal choice to allow flexibility cannot be undone by state tort law mandating a specific design.
Significance
Geier v. American Honda Motor Co. is the leading case on obstacle preemption in the products liability context and is regularly contrasted with Wyeth v. Levine (no preemption where compliance was possible and federal purpose was not frustrated). The case is also notable for its treatment of a saving clause (which preserved some state tort suits) as not foreclosing implied conflict preemption analysis. The dissent’s sharp criticism has influenced how later courts approach implied preemption.