Geier v. American Honda Motor Co. Case Brief Summary | Law Case Explained

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Geier v. American Honda Motor Co. | 529 U.S. 861 (2000)

The interplay between federal statutory and regulatory law on one hand, and state common law on the other hand, came in for consideration in Geier versus American Honda Motor Company.

Pursuant to the National Traffic and Motor Vehicle Safety Act of 1966, the Department of Transportation has issued Federal Motor Vehicle Safety Standards, which we’ll call the standards. The department regularly updates the standards as cars evolve, safety technology becomes available, and as conditions warrant. Standard number 208 regulates passenger crash protection and regulates active passenger restraints, such as seatbelts and shoulder harnesses, and passive restraints, such as airbags and automatic seat belts. The 1984 version of standard 208, which applied to cars built in 1987, gave carmakers the option whether or not to install passive restraints.

In 1992, Alexis Geier, driving her 1987 Honda Accord, collided with a tree. Despite wearing her seatbelt and shoulder harness, Geier suffered serious injuries. Geier sued Honda, alleging that her Accord was negligently and defectively designed because it lacked a driver’s-side airbag.

Honda responded that Geier’s Accord complied with standard 208, which therefore preempted local standards. The district court dismissed Geier’s lawsuit, holding that Geier was trying to establish a safety standard different than standard 208, and that the act preempted standards other than those established by the department. The court of appeals affirmed, and the United States Supreme Court granted Geier’s cert petition.

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