Rear-seat belt requirements
Williamson v. Mazda Motor of America
In brief
The Supreme Court overturned the California appeals court and said federal safety rules do not block the Williamsons' state claim over rear-seat belts.
- Where it stands
- Decided
Decided 8-0 · February 23, 2011 · Opinion by Justice Breyer
- What it’s about
- The Supreme Court ruled that federal safety standard 208 did not block the Williamsons’ state-law lawsuit claiming Mazda should have installed lap-and-shoulder belts, rather than lap belts, on rear inner seats.
- Who it affects
- Federal standard 208 does not block the Williamsons' state-law claim over rear inner-seat belts, but the Court did not decide whether Mazda is liable.
Summary: written with AI from the case record.
What it's about
It overturned the California appeals court’s ruling (reversed it).
Federal standard 208 let manufacturers choose between lap-only and lap-and-shoulder belts for some seating positions.
Question presented
1. Where Congress has provided that compliance with a federal motor vehicle safety standard does not exempt a person from liability at common law, 49 U.S.C. § 30103(e), does a federal minimum safety standard allowing vehicle manufacturers to install either lap-only or lap/shoulder seatbelts in certain seating positions impliedly preempt a state common-law claim alleging that the manufacturer should have installed a lap/shoulder belt in one of those seating positions? 2. Under this Court's recent ruling in Wyeth v. Levine , _ S. Ct. _, 2009 WL 529172 (2009), does a federal motor vehicle safety standard allowing vehicle manufacturers to install either lap-only or lap/shoulder seatbelts impliedly preempt a state tort suit alleging that the manufacturer should have warned consumers of the known dangers of a lap-only seatbelt installed in one of its vehicles?
What the Court decided
Holding
FMVSS 208 does not pre-empt state tort suits claiming that manufacturers should have installed lap-and-shoulder belts, instead of lap belts, on rear inner seats. 167 Cal. App. 4th 905, 84 Cal. Rptr. 3d 545, reversed.
- Result
- Reversed
The vote
- Joined the judgment
- Concurred in a separate opinion
- Wrote an opinion
- Majority · 7joined the Court's opinion
- Concurring · 1agreed with the result, wrote separately
- Thomaswrote separately
What's next
The Williamsons' state-law claim remains unresolved; the Supreme Court decided only that federal standard 208 does not block it.
Documents
Opinions
Audio
Docket activity
New analysis added
AI analysis generated: Case Briefing
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
Show 5 moreShow fewer
AI analysis generated: Decision Record
Case data updated: question_presented, extraction_metadata
Case data updated: summary, question_presented, generation_metadata
Audio Recording added: Oral Arguments - Williamson
Opinion added: Williamson
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.