Supreme Court of the United States
Sprietsma v. Mercury Marine, a Division of Brunswick Corp.
December 3, 2002537 U.S. 51
Summary
Justice Stevens delivered the unanimous opinion holding that the Federal Boat Safety Act does not pre-empt state common-law damages claims alleging that an outboard motor was defective because it lacked a propeller guard. The Act’s express pre-emption clause addresses legislative and regulatory enactments, not common-law claims, and its saving clause preserves common-law liability. The Coast Guard’s decision not to require propeller guards did not establish a federal policy against them, and neither the statutory scheme nor its interest in uniformity displaced these common-law remedies. The Court reversed the Illinois Supreme Court and remanded without deciding the merits or viability of the claims under Illinois law. There were no separate opinions.
Holding
- Express pre-emption of state common-law claims under the Federal Boat Safety Act.. The Act’s express pre-emption clause does not encompass the petitioner’s state common-law tort claims.
- Conflict pre-emption arising from the Coast Guard’s decision not to require propeller guards.. The Coast Guard’s refusal to promulgate a propeller-guard requirement did not pre-empt the petitioner’s claims.
- Implied pre-emption under the Act’s overall regulatory scheme and uniformity objectives.. The Act does not occupy the field so completely as to foreclose these state common-law remedies, and its uniformity objective does not independently require their displacement.
Docket 01-706
Cited authorities
- 46 U.S.C. §§4301-4311
- CA11
- 46 U.S.C. §§4301-4311
- 36 Stat. 462
- 40 Stat. 602
- 54 Stat. 163
- 72 Stat. 1754
- Pub. L. 92-75, §2
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