Last week, the U.S. Supreme Court ruled that the family of a passenger that was killed in a car accident while wearing a lap-only seat belt could bring a lawsuit against the vehicle manufacturer. The plaintiffs argued that by manufacturing the vehicle without shoulder belts for all passengers, the manufacturer was negligent in its design of the vehicle. The manufacturer, Mazda, argued that the family was barred from bringing a lawsuit because the company had complied with federal seat belt regulations in place at the time the vehicle was made.
The case arose from a fatal car accident in 2002. A woman riding in the center rear seat of a Mazda minivan was killed during a head-on collision. She was wearing the lap belt which was the only safety restraint available to a passenger in that seat. Other passengers in the car who were wearing combination lap and shoulder belts survived the crash.
The case was originally filed in state court and preliminary rulings agreed with Mazda that it was protected from this type of lawsuit by abiding by the federal regulations. The U.S. Supreme Court disagreed; reasoning that the Department of Transportation's regulations on the use of lap only seat belts in rear-center seats was based on cost effectiveness rather than safety. Therefore, the regulation does not demonstrate that the DOT was trying to block common law tort cases based on the manufacturer's choice to use lap belts.
A concurring opinion pointed out that the National Traffic and Motor Vehicle Safety Act of 1966 explicitly states that compliance with regulations propagated under that Act does not immunize a manufacturer from common law liability.
Source: Chicago Tribune "Supreme Court to let family sue Mazda over mother's death in seat belt" Jesse Holland, February 23, 2011