Geier v. American Honda Motor Co., Inc.

Summary

Justice Breyer, joined by Chief Justice Rehnquist and Justices O'Connor, Scalia, and Kennedy, held that the plaintiffs' claim that their 1987 Honda Accord should have contained an airbag was preempted because it conflicted with the deliberate federal policy of gradually introducing a mix of passive restraint systems. Although the Safety Act's express preemption provision did not encompass common-law tort actions, its saving clause did not prevent ordinary conflict preemption or impose a special burden against it. A formal agency statement of preemptive intent was unnecessary to establish an actual conflict. Justice Stevens dissented, joined by Justices Souter, Thomas, and Ginsburg, arguing that Honda had not overcome the presumption against preemption, that the claim would not frustrate the regulation's safety objectives, and that regulatory history and litigation positions were inadequate grounds for displacing state tort remedies.