In an important case for manufacturers, the Supreme Court held 5/22/2000 that Federal Motor Vehicle Safety Standard 208, promulgated under the National Traffic and Motor Vehicle Safety Act of 1966, preempts state tort claims based upon a manufacturer's failure to install airbags in a 1987 model automobile. The Court held that the Safety Act's "savings" provision excludes common-law tort claims from express preemption. But the Court also held that the Safety Act's savings provision neither "bar[red] the ordinary working of conflict pre-emption principles" nor imposed a "'special burden' beyond that inherent in ordinary pre-emption principles." Applying those principles, the Court held that common-law airbag claims, which effectively seek to require airbag installation, would stand "as an obstacle to the accomplishment and execution of" Standard 208's objective to "provid[e] the manufacturer with a range of choices among different passive restraint devices." Accordingly, such claims are preempted.
Justice Stevens, joined by Justices Souter, Thomas, and Ginsburg, dissented, arguing that the presumption against preemption of state law militated against finding any implied conflict preemption in this case.