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Federal Courts -
U. S. Supreme Court - May 22 - May 30, 2000
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Geier v. Am. Honda Motor Co., No. 98-1811,
SUPREME COURT OF THE UNITED STATES, May 22, 2000, Decided
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Overview: Petitioner driver collided with a tree and was seriously injured. Petitioners, the driver and her parents, sued respondent car manufacturer, claiming that respondent had designed its car negligently and defectively because it lacked a driver's side airbag. The district court dismissed the suit, and the court of appeals affirmed. The court granted certiorari and affirmed the dismissal. The court found that the National Traffic and Motor Vehicle Safety Act of 1966, former, express preemption provision did not preempt the common-law "no airbag" action because the language permitted a narrow reading that excluded common-law actions. However, the court found that petitioners' suit conflicted with Federal Motor Vehicle Safety Standard (FMVSS) 208. FMVSS 208 sought a gradually developing mix of alternative passive restraint devices for safety-related reasons. The rule of state tort law for which petitioners argued would have stood as an obstacle to the accomplishment of that objective, and the statute foresaw the application of ordinary principles of preemption in cases of actual conflict. Hence, petitioners' action was pre-empted.
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Vt. Agency of Natural Res. v. United States ex rel. Stevens, No. 98-1828,
SUPREME COURT OF THE UNITED STATES, May 22, 2000, Decided
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Overview: Respondent relator, a former employee of petitioner state agency, brought a qui tam action under the False Claims Act (FCA) against petitioner, alleging that petitioner submitted false claims to a government agency in connection with various federal grant programs. Petitioner moved to dismiss, arguing that petitioner was not a person subject to liability under the FCA and that the qui tam action was barred by. The district court denied the motion to dismiss, and the appellate court affirmed. On writ of certiorari, the Court reversed the judgment. The Court determined that respondent relator had standing to bring suit in federal court on behalf of respondent United States under the FCA, but that the FCA did not subject petitioner to liability in the action. The term "person" in the FCA did not include states for purposes of qui tam liability.
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