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Freightliner Corp. v. Myrick, 514 U.S. 280, 115 S.Ct. 1483, 131 L.Ed.2d 385, 63 USLW 4263, Prod.Liab.Rep. (CCH) P 14,182

Facts

This case arises from two separate but essentially identical accidents in Georgia involving tractor-trailers. In both cases, 18-wheel tractor-trailers attempted to brake suddenly and ended up jackknifing into oncoming traffic. Neither vehicle was equipped with an antilock braking system (ABS). In the first case, respondent Ben Myrick was the driver of an oncoming vehicle that was hit by a tractor-trailer manufactured by petitioner Freightliner, leaving him permanently paraplegic and brain damaged. In the second case, Grace Lindsey was killed when her vehicle collided with a tractor-trailer manufactured by petitioner Navistar. Respondents independently sued the manufacturers under state tort law, alleging that the absence of ABS constituted a negligent design defect.

This case arises from two separate but essentially identical accidents in Georgia involving tractor-trailers. In both cases, 18-wheel tractor-trailers attempted to brake suddenly and ended up jackknifing into oncoming traffic. Neither vehicle was equipped with an antilock braking system (ABS).

Issue

Whether the National Traffic and Motor Vehicle Safety Act expressly or implicitly preempts state common-law claims for design defects in vehicles not equipped with antilock braking systems.

Whether the National Traffic and Motor Vehicle Safety Act expressly or implicitly preempts state common-law claims for design defects in vehicles not equipped with antilock braking systems.

Rule

The Safety Act's express pre-emption clause applies only when a federal motor vehicle safety standard is in effect regarding the same aspect of performance regulated by a state standard. The absence of a federal standard does not constitute regulation, and state common-law actions are not preempted if they do not conflict with federal law.

The Safety Act's express pre-emption clause provides: 'Whenever a Federal motor vehicle safety standard established under this subchapter is in effect, no State or political subdivision of a State shall have any authority either to establish, or to continue in effect, with respect to any motor vehicle or item of motor vehicle equipment any safety standard applicable to the same aspect of performance of such vehicle or item of equipment which is not identical to the Federal standard.'

Analysis

The court found that the National Traffic and Motor Vehicle Safety Act did not preempt the respondents' common-law claims because there was no federal standard in effect regarding stopping distances or vehicle stability for trucks. The absence of a federal standard meant that states could establish their own safety standards. Furthermore, the court determined that the respondents' claims did not conflict with federal law, as there was no federal regulation governing the use of ABS devices, allowing for the coexistence of state common-law actions.

The court found that the National Traffic and Motor Vehicle Safety Act did not preempt the respondents' common-law claims because there was no federal standard in effect regarding stopping distances or vehicle stability for trucks.

Conclusion

The Supreme Court affirmed the Eleventh Circuit's decision, holding that the National Traffic and Motor Vehicle Safety Act did not preempt state common-law claims regarding design defects in vehicles lacking antilock braking systems.

The Supreme Court affirmed the Eleventh Circuit's decision, holding that the National Traffic and Motor Vehicle Safety Act did not preempt state common-law claims regarding design defects in vehicles lacking antilock braking systems.

Who won?

Respondents prevailed in the case because the Supreme Court ruled that their common-law claims were not preempted by federal law, allowing them to pursue their design defect claims against the manufacturers.

Respondents prevailed in the case because the Supreme Court ruled that their common-law claims were not preempted by federal law.

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