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Legislative Process Keyed to Bressman, 4th Ed.
Geier v. American Honda Motor Co.
Citation:
529 U.S. 861 (2000)Facts
In 1992, Alexis Geier was driving a 1987 Honda Accord when she collided with a tree and suffered serious injuries. Although she was wearing her manual seatbelt at the time, the car was not equipped with an airbag or other passive restraint device. Geier and her parents sued American Honda Motor Company under District of Columbia tort law, alleging that the car was negligently and defectively designed because it lacked a driver’s side airbag. The 1987 Honda Accord complied with Federal Motor Vehicle Safety Standard 208, which at that time required manufacturers to equip only 10% of their 1987 model year fleet with passive restraints (such as airbags or automatic seatbelts). Honda had met this requirement by installing passive restraints in other 1987 models. The Safety Act contained both an express preemption provision prohibiting states from establishing safety standards not identical to applicable federal standards, and a saving clause stating that compliance with a federal safety standard does not exempt anyone from liability under common law.
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