Mazda Seat Belt Case to go to Trial After Woman Dies – Williamson v. Mazda

The United States Supreme Court has ruled that a family is allowed to pursue its lawsuit in California against Mazda Motors of American, Inc. in the case of The Estate of Thanh Williamson v. Mazda, 08-1314. The product liability lawsuit deals with claims that the auto company’s 1993 Mazda MPV minivan were unsafe because the middle seat of the vehicle’s second row was only equipped with lap seat belts.

The wrongful death lawsuit was filed after Thanh Williamson, a Utah mother, died in a 2002 auto crash. Mrs. Williamson was seatbelted into the back middle seat of the family’s Mazda minivan at the time of the car crash. According to eyewitnesses of the car accident, the impact of the car crash caused Mrs. Williamsons’s body to jackknife around the lap seat belt, which resulted in her fatal internal injuries.

Again, central to the estate’s product liability claim was that the seatbelt the late Mrs. Williamson was using was not equipped with a harness or shoulder belt. However, this option is not required by federal regulations. While federal law does require that a vehicle’s front and rear outer seats come equipped with both lap and shoulder belts, car manufacturers may decide whether or not to also provide this option in their middle or aisle seats.

Mazda argued in the case that it was immune from seat belt lawsuits because the federal government in 1989 gave Mazda a choice of installing either a lap or lap and shoulder seat belts in the middle rear seat. Mazda claimed that the product liability lawsuit forcing it to use lap and shoulder belts would invalidate that choice that was given to it back in 1989. The California state courts had agreed with Mazda’s arguments and threw out the families’ lawsuit. To support its position, Mazda cited a 2000 U.S. Supreme Court decision that dismissed lawsuits that tried to force car manufacturers to install airbags.

But Supreme Court Justice Stephen Breyer, who wrote the majority opinion in this product liability case, said that the only way Mazda would be immune is if the “significant objective” of the federal regulation that Mazda relied upon was to give all of the manufacturers a choice of which seat belts to install. But the transportation department “gave no indication that its safety goals required the mixture of seat belt types that resulted from manufacturers’ ability to choose different options,” said Justice Sotomayor in the concurring opinion.

Justice Breyer also noted, “The more important reason why DOT did not require lap and shoulder belts for rear inner seats was that it thought that this requirement would not be cost-effective. The agency explained that it would be significantly more expensive for manufacturers to install lap and shoulder belts and rear middle and aisle seats than seats next to the car doors. But that fact – the fact that DOT made a negative judgment about cost effectiveness – cannot by itself show that DOT sought to forbid common law tort suits in which a judge or jury might reach a different conclusion.”
Justice Clarence Thomas agreed with the majority decision and also noted that the National Traffic and Motor Vehicle Safety Act of 1966 made coming to the decision easier.

Justice Thomas said that Congress had instructed that compliance with the motor vehicles safety standard did not exempt Mazda from liability at common law. Justice Thomas said, “This saving clause ‘explicitly preserves state common-law actions.’ . . . According to Mazda, the Williamsons’ product liability lawsuit alleged that it should have installed a lap and shoulder belt, instead it is preempted. That argument is foreclosed by the saving clause; the Williamsons’ state tort action is not preempted.”
It should be noted that there was commentary by industry analysts who said that there is some concern by the auto manufactures that with this decision would come the possibility of other similar lawsuits.

Chicago’s Kreisman Law Offices has been handling Illinois product liability cases and Cook County wrongful death lawsuits for more than 35 years in and around Chicago, Illinois, Cook County and surrounding areas including, Deerfield, Evanston, Oak Park, Willowbrook and Elmhurst, Illinois.

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