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Federal Regulation of Seat Belts Preempted Defect Design and Failure to Warn Claims
Description Appeals court affirmed dismissal of wrongful death suit brought by survivors of motorist killed in an accident. Their claim that the seat belt was improperly designed and that the car maker had failed to warn of the need to wear a lap belt was preempted by the maker's compliance with federal regulations concerning seat belts.
Topic Torts
Key Words Product Liability; Federal Preemption
C A S E   S U M M A R Y
Facts The survivors of Owolabi, who was killed when her car was forced off the road and crashed, sued Mazda, the maker of the car she was driving, for wrongful death. The car had a shoulder belt that was automatic; the lap belt was manual. Owolabi had not fastened the lap belt. Plaintiffs contended that Mazda had failed to warn consumers of the need to fasten the lap belt and that it was defectively designed. District court entered summary judgment for Mazda. Plaintiffs appealed.
Decision The seat belt design complied with Federal Motor Vehicle Safety Standard 208 issued under the National Traffic and Motor Vehicle Safety Act. Under the Standard, carmakers had several options as to how seat belts could be designed; Mazda legally followed one of the options. The existence of the regulation, and the following of the regulation by Mazda. impliedly preempted state law claims that the seat belt was defectively designed and that Mazda was negligent for failure to warn of the need to use the lap belt.
Citation James v. Mazda Motor Corp., 2000 WL 1175026 (11th Cir., 2000)

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