The case whose proceedings were held at the State Appeal Court involved the Williamson family who were accusing a car manufacturer of failing to install seat belts at the back seats of their buses as stipulated in a directive from the Federal Vehicle Safety Standard. According to this law, auto manufacturers are required to install lap and shoulder belts on the seats located near the vehicles doors or frames, but leaves them the option of installing shoulder belts or simple lap belts on the seats located at the middle of the bus.
In the suit filed in November last year and determined last month, the court was notified that Thanh Williamson had died in a road accident because Mazda Motors who were the defendants had installed lap belts in the bus instead of lap-and-shoulder belts, which were safer. In its ruling, the State Trial Court ruled in favor of the defendant. Upon losing the suit, the Williamson family moved to the State Court of Appeal, which affirmed the State Trial Court ruling.
In its ruling, the State Court of Appeal relied on an earlier ruling on Geier V. American Honda Motor Co, where the court exonerated Honda from accusations of flouting an earlier version of FMVSS, which demanded the installation of passive restraint devices. In the ruling, the court had exemplified that car manufacturers were under no obligation to install airbags. (Cornell University Law School)
The State Court of Appeal held that the FMVSS directive did not prevent cases such as the one where Mazda Motor Company was being accused of failing to fit lap-and shoulder belts in the inner aisles of their minivans. In upholding the ruling, the court claimed that the case was set on the same precedent as Geier’s and that it was only an afterward fashion of the same directive.
In its judgment, the court of appeal quoted the Hines v. Davidowitz ruling, which declared that any state law standing as an obstacle to the execution of a federal law is overruled. In Geier’s case, the court observed that the regulation had left the manufacturer a choice of choosing whether to install airbags or not. However, the Williamson case did not have a direct resemblance to that of the Geier case observed earlier.
In 1984, the Department of Transport (DOT) had rejected a directive that required back seats to be fitted with Lap-and-shoulder belt. Five years later, DOT revised the directive and stipulated that manufacturers should fit lap-and-shoulder belts for outer back seats but gave the manufacturers the choice to decide the nature of the belts in the inner aisles. According to DOT, this was meant to ensure that the manufacturers were not presented with additional costs.
Personally, this case is of much interest to me because it addresses the safety of the common person. It is obvious from the Williamson suit that Thanh died as a direct result of the manufacturer installing lap belts instead of lap-and-shoulder belts. As a judge, I would have given a guilty judgment since relying on 1989 regulations to base ones argument is obviously outdated.
By giving a guilty judgment, manufacturers would be forced to come up with regulations that promote consumer acceptance and not merely the ones that are cost effective. It is obvious that the state law in this case conflicts with the federal law but in this instance the court should have given eminence on the state law since the costs involved in fixing seat belts were not as significant as those involved in installing airbags were.
Cornell University Law School. Supreme Court of the United States, 2011. Web. March 9, 2011.