Melissa Varela v. Fca US LLC

Summary

The Arizona Supreme Court held that the plaintiff’s negligence, products-liability, warning, and wrongful-death claims based on the alleged failure to install automatic emergency braking were not impliedly preempted. The administrative record did not establish an authoritative federal policy requiring manufacturer choice, leaving AEB unregulated, or excluding state tort liability, and the claims did not conflict with the federal objective of encouraging broader and faster AEB deployment. The court affirmed the court of appeals, vacated part of its opinion, reversed the trial court’s dismissal order, and remanded for further proceedings.