Case background and facts
The attorney general of California filed a case against Mazda Motor Vehicle Corporation after an accident that resulted in the killing of Thanh Williamson in 2002. Williamson was driving a Mazda MPV minivan model of 1993 and she was wearing a lap-only seat belt installed in the vehicle. The seat belt in this case was not effective since after a collision with another vehicle, it did not play a role in saving Williamson’s life. According to the petitioner in this case, the safety standard of Mazda MPV was poor because the driver’s life was not guaranteed for safety due to the installation of seat belts that were ineffective. But according to the respondent, vehicle safety standards were established by the federal regulations that protected automakers from law suits that were related to product reliability. In this case, the petitioner felt that it was not worth to plead guilty due to the protection provided by the federal regulations.
The case was presented to two lower courts in California. After the petitioner presented the case, there were many factors to consider since according to the federal regulations governing the vehicle safety standards, the automakers were supposed to install lap-only seat belts. According to Hingson & Howland (2009) “the two California courts ruled that the plaintiffs’ lawsuit couldn’t proceed because it was preempted by a Federal Motor Vehicle Safety Standard under the National Traffic and Motor Vehicle Safety Act that authorized automakers to install lap-only seat belts”. The national-traffic and motor-vehicle-safety act was established in the US in the year 1966 and it was meant to facilitate the federal government to provide and enforce safety standards meant to ensure that road safety is guaranteed for the motorists. One such safety measure introduced was the installation of lap-only safety belts in all vehicles. These safety standards were effective in that the caused a decrease of death from 18/100 million vehicle miles in the year 1924 to 1.7 per one hundred million vehicle miles traveled, this is equivalent to ninety percent decrease (Graham, 2008). According to the national traffic and motor vehicle safety act, each motor vehicle manufacturing company had to meet the set of the required safety standards before being awarded the license to carry people. Meeting these standards offered the automakers protection by the law. Graham (2008) added that “by the year 1970, motor-vehicle-related death rates were decreasing by both the public health measure and the traffic safety indicator.” However, in September 2007 the relevant regulations related to safety belt-installations changed and now vehicles that are meant for transporting passengers are required to install shoulder and lap seat-belts in the rear seating-positions which face the forward side (Graham, 2008).
Court ruling
The reference case could therefore not be decided easily at the lower courts and therefore had to be listened to by the Supreme Court. This was because there were conflicting laws on whether motor vehicle safety act offered protection to Mazda Motor Vehicle Corporation. Connor, Sabato &Yanus (2009) stated that “the U.S. Supreme Court agreed to decide whether federal regulations establishing vehicle safety standards should prevent product liability lawsuits against automakers for installing lap-only seat belts”. The solicitor general of the Supreme Court was Elena Kagan. The solicitor general was faced with a hard task in giving the ruling for this case. This was because there were many factors to consider when making the decision that would ensure justice for all the sides. First, the lower courts made the decisions correctly according to their interpretation of the National Traffic and Motor Vehicle Safety Act. Secondly, the National Traffic and Motor Vehicle Safety Act was established as a law by the government and was therefore to be respected. According to the solicitor general, justice would take course in the case by contending that both the lower federal-courts and the state courts made a broad interpretation of the federal law by barring law-suits against automakers who installed lap only seat belts. According to Connor, Sabato &Yanus (2009) “the solicitor general of the Supreme Court ruled that The lower courts’ methodological error was important and it effectively deprived the Safety Act’s savings clause of its proper effect.” In addition, the lower court changed the FMVSS from a low level into a definitive care standard. The lower court did this contrary to the position of the agency which was responsible for promulgating the standards. From this argument, the solicitor general indicated that the presented question required government intervention. The solicitor general considered the common law during the ruling, according to 49 U.S.C. § 30103(e) which is a minimum safety standard of the common law, the vehicle manufacturing companies should install lap/shoulder seat belts in the vehicles. Therefore the common federal law did not preempt someone liability to common law and therefore Mazda Motor Vehicle Corporation was supposed to provide such an installation in Thanh Williamson’s Mazda minivan and this would have saved her life.
Ideological issues
The case invoked ideological issues that are worth mentioning. For the liberal side, the respondent should have installed both the lap and shoulder safety belt as the common law required. But for the conservative side, the respondent was protected by the vehicle safety act that stated that a vehicle should have either lap-only seat belt or shoulder belt.
Personal opinion
Mazda Motor Vehicle Corporation acted in a conservative way. The failure to install shoulder seat belts and instead install lap-only seat belts as required by the motor vehicle safety act was a mistake. This is because the common law and the safety measures required that motor vehicles should ensure passenger safety by installing both lap and shoulder safety seat belt. The company should have therefore taken measures above what was required by the traffic act and provided such a measure that would have not extra cost and ensured higher levels of safety.
Precedent and evaluation of the court impact
This reference case relied on the precedent provided by the petitioner Thanh Williamson. The case was first heard in two lower courts which were not able to address the reference question. The current case therefore can set future precedent because the decision on similar cases can be based on the ruling of the solicitor general of the Supreme Court. The ruling of this case therefore implies that cases should first broadly interpret the governing federal and common laws which are considered when courts make their rulings.
The case is important in relation to class work because it helps in the understanding of the changes taking place within the United States constitution. Connor, Sabato &Yanus (2009) argued that “the Living Constitution boxes appeared at the beginning of every chapter to examine the chapter’s topic in light of what the Constitution says—or fails to say—about it”.. From this perspective one is able to notice what is not covered in the constitution and therefore one can be in a position to decide what should be added into it so as to make it effective (Connor, Sabato &Yanus, 2009). For instance, in the reference case, there was lack of clarity on whether the motor vehicle companies should install shoulder safety belts. Therefore by good understanding of the constitution, one can realize the deficiency that existed in the National Traffic and Motor Vehicle Safety Act.
References
- Connor, K.O., Sabato, L. J. &Yanus, A. (2009). Essentials of American Government: Roots and Reform. Ninth Edition. New York: Pearson/Longman.
- Graham, J. D., (2008). Preventing Automobile Injury: New Findings from Evaluation Research. Dover: Auburn House Publishing Company.
- Hingson, R. & Howland, J. (2009). Accident facts. Itasca, Illinois: National Safety Council.