Doomes v. Best Transit Corp.
New York Court of Appeals
958 N.E.2d 1183 (2011)
After a bus operated by Best Transit (defendant) and manufactured by Warrick Industries (defendant) rolled over when its driver fell asleep, injuring passenger Gloria Doomes and others (plaintiffs), the injured passengers sued alleging their injuries resulted from the bus's lack of passenger seatbelts. Warrick argued the claims were preempted because Federal Motor Vehicle Safety Standard (FMVSS) 208 governed bus seatbelt requirements, and after the jury found Warrick liable, the appellate division agreed the claims were federally preempted and reversed.
Whether a plaintiff's state-law claim is preempted by federal law when Congress did not expressly provide for preemption, the state law does not conflict with the federal law, Congress did not intend to fully occupy the relevant subject area, or the federal law is silent as to the state-law claim.