The U.S. Supreme Court has ordered a South Carolina court to reconsider its ruling that a suit against Ford Motor Company over allegedly defective windows is preempted by federal law. This decision follows the recent decision by the Court in a similar case against Mazda Motor Corp. The Justices held that their ruling in the Mazda case, which involved defective seat belts, meant the Ford decision by the South Carolina Supreme Court had to be revisited.
In the Mazda case, the Court ruled that federal car safety standards do not preempt state tort claims over injuries when the federal regulations are aimed at setting a minimum safety standard. The Justices correctly said that Plaintiffs cannot be barred from seeking damages at the state level for a company’s failure to go above that minimum standard.
Though the cases involved window glass rather than seat belts, similar claims are at issue in this South Carolina case, the High Court ruled. The Court vacated the South Carolina court’s ruling and remanded the case for further consideration. Both cases involve Federal Motor Vehicle Safety Standards that give carmakers the option of using two different types of safety features. In the Mazda case, it was a choice between lap seat belts and lap/shoulder belts. This South Carolina case deals with a choice between either tempered or laminated glass in the side windows of cars.
The South Carolina case was brought by Mary Robyn Priester, whose son James Priester was killed in a crash in 2002 when he was ejected from the side window of a 1997 Ford F-150. It was contended that the truck was defectively designed because its side windows were made of tempered glass, which shatters on impact, rather than laminated glass, which holds together on impact and is designed to prevent ejections. As with the Mazda case, the issue hinges on the extent to which federal regulations that give carmakers options on which safety features to include, preempt state law claims alleging a vehicle is defective for failing to choose one particular option.
The National Highway Traffic Safety Administration at one point considered requiring laminated glass in the side windows of all vehicles, but rejected that proposal in 2002, finding it would be too expensive for manufacturers. But, the agency cited the safety benefits of laminated glass and permits its use in vehicle windows, as well as the use of tempered glass. The South Carolina Supreme Court held that the claims in the Priester case were preempted because they conflict with the federal safety standard giving automakers a choice of glass.
The U.S. Supreme Court ruled in the Mazda case that the seat belt regulation was aimed at setting a minimum safety standard, and that giving carmakers a choice was not a significant regulatory objective. As a result, the Court ruled that the regulation does not preempt the state law claims.
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