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Administrative Law Keyed to Mawshaw
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. The car was equipped with manual lap and shoulder belts, which Geier had buckled, but it did not have an airbag or any other passive restraint system. Geier and her parents sued Honda under District of Columbia tort law, claiming that the car was negligently and defectively designed because it lacked a driver’s side airbag. At the time the car was manufactured, Federal Motor Vehicle Safety Standard 208 required manufacturers to equip only 10% of their 1987 model year fleet with passive restraints. Honda had complied with this requirement by installing passive restraints in other 1987 models. The standard was part of a deliberate regulatory scheme that provided manufacturers with a choice among different passive restraint technologies and established a gradual phase-in schedule. The Department of Transportation had specifically rejected an “all airbag” standard, preferring instead to encourage a mix of different passive restraint systems that would be introduced gradually to overcome technical problems, reduce costs, and build public acceptance.
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