Freightliner Corp. v. Myrick
Headline: Court allows state negligence suits over missing anti-lock brakes, ruling a suspended federal safety standard does not block state claims, so injured motorists can sue truck manufacturers.
Holding:
- Allows injured motorists to sue truck manufacturers over lack of ABS.
- Leaves state safety rules and tort liability intact absent a federal standard.
- Encourages NHTSA to decide whether to adopt new federal stopping-distance standards.
Summary
Background
Two people in Georgia sued truck manufacturers after separate accidents in which 18-wheel tractor-trailers jackknifed into oncoming traffic. One victim, Ben Myrick, was left paraplegic and brain damaged. Another, Grace Lindsey, was killed. The plaintiffs said the trucks were negligently designed because they lacked anti-lock braking systems (ABS). The manufacturers removed the cases to federal court and argued that the National Traffic and Motor Vehicle Safety Act and related federal rules barred the state-law claims. Lower courts split: a district court sided with the manufacturers, but the Court of Appeals for the Eleventh Circuit reversed and allowed the suits to proceed.
Reasoning
The Court asked whether a federal motor-vehicle safety standard was "in effect" for truck stopping distances and vehicle stability. It found no such federal standard currently in effect. A prior Standard 121 had been suspended after a court found the agency had not shown that ABS was safe, and NHTSA never reinstated a minimum, objective standard. Because no federal standard governs stopping distance or ABS, the Act’s express pre-emption clause does not apply. The Court also rejected the manufacturers’ argument for implied conflict pre-emption, explaining that it is possible to comply with both state and federal law when no federal requirement exists and that state liability would not frustrate Congress’s purposes.
Real world impact
The decision means victims can pursue state negligence lawsuits against truck makers over the lack of ABS despite the earlier federal rulemaking and court suspension. The ruling leaves regulation and liability tied to existing state law unless NHTSA adopts a new, operative federal standard.
Dissents or concurrances
Justice Scalia agreed with the judgment.
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