Geier v. American Honda Motor Co.
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OR:

''Geier v. American Honda Motor Company'', 529 U.S. 861 (2000), was a
United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
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 The , also known as the in Japan and China for certain generations, is a series of cars manufactured by Honda since 1976, best known for its four-door sedan variant, which has been one of the best-selling cars in the United States since 1989. ...
, could not sue
Honda is a Japanese public multinational conglomerate manufacturer of automobiles, motorcycles, and power equipment, headquartered in Minato, Tokyo, Japan. Honda has been the world's largest motorcycle manufacturer since 1959, reaching a producti ...
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 airbag. 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 The National Traffic and Motor Vehicle Safety Act was enacted in the United States in 1966 to empower the federal government to set and administer new safety standards for motor vehicles and road traffic safety. The Act was the first mandatory fede ...
. The
United States Court of Appeals for the District of Columbia Circuit The United States Court of Appeals for the District of Columbia Circuit (in case citations, D.C. Cir.) is one of the thirteen United States Courts of Appeals. It has the smallest geographical jurisdiction of any of the U.S. federal appellate co ...
affirmed.


Decision of the Supreme Court

Justice Stephen G. Breyer delivered the Court's 5–4 decision, which held: " eier'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."''Geier'', 529 U.S. at 913 (Stevens, J., dissenting).


See also

* '' Honda Motor Company v. Oberg'' *
List of United States Supreme Court cases, volume 529 This is a list of all the Supreme Court of the United States, United States Supreme Court cases from volume 529 of the ''United States Reports'': External links

{{SCOTUSCases, 529 2000 in United States case law ...


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 The University of Michigan Press is part of Michigan Publishing at the University of Michigan Library. It publishes 170 new titles each year in the humanities and social sciences. Titles from the press have earned numerous awards, including ...
, 2010.


External links

* United States Supreme Court cases United States Supreme Court cases of the Rehnquist Court 2000 in United States case law Airbags Honda Product liability case law {{SCOTUS-stub