Supreme Court of the United States
Freightliner Corp. v. Myrick
April 18, 1995514 U.S. 280
Summary
The Court, in an opinion by Justice Thomas, held that state common-law claims alleging negligent failure to install antilock braking systems on tractor-trailers were neither expressly nor impliedly preempted by federal law. The relevant federal safety requirements had been suspended, leaving no operative standard that could expressly preempt state requirements or conflict with the tort claims. The Court also rejected the argument that an express preemption clause categorically forecloses implied preemption. It affirmed the Eleventh Circuit’s judgment reversing summary judgment for the manufacturers. Justice Scalia concurred in the judgment without a separate written opinion.
Holding
- Express preemption in the absence of an operative federal safety standard.. The Safety Act does not expressly preempt the state negligent-design claims because no applicable federal standard governing truck and trailer stopping distances or vehicle stability is in effect.
- Whether an express preemption clause excludes implied preemption.. An express preemption clause does not categorically foreclose implied preemption.
- Conflict preemption of the state negligent-design claims.. The state common-law claims are not impliedly preempted.
Docket 94-286
Cited authorities
- CA11
- 36 FR 3817
- Pub. L. 89-563, 80
- 15 U.S.C. § 1381
- 15 U.S.C. § 1381
- 49 C.F.R. § 1.50
- 44 FR 46849
- 15 U.S.C. § 1392
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