Geier v. American Honda Motor Co.

Alexis Geier suffered severe injuries in a 1987 Honda Accord that did not possess a driver's side airbag.

Geier and her family sought damages under the District of Columbia tort law "claiming that American Honda Motor Company was negligent in not equipping the Accord with a driver's side airbag."

The District Court ruled in favor of Honda finding that "Geier's claims were expressly pre-empted by the Act."

[3] Justice Stephen G. Breyer delivered the Court's 5–4 decision, which held: "[Geier's] 'no airbag' lawsuit conflicts with the objectives of FMVSS 208 and is therefore pre-empted by the Act.

"[4] The dissent challenged the majority's "unprecedented use of inferences from regulatory history and commentary as a basis for implied pre-emption.