MCI Sales and Service, Inc. v. Hinton

Summary

The Supreme Court of Texas held that federal motor vehicle safety standards did not preempt state common-law claims alleging that a motorcoach should have had passenger seatbelts and laminated-glass windows. The court also held that a bankruptcy-court plan allocating a debtor's insurance proceeds rendered the debtor a settling person under Chapter 33 of the Texas Civil Practice and Remedies Code for proportionate-liability purposes. The court affirmed the court of appeals' judgment and remanded for further proceedings.

Holdings

1. Regulatory silence does not preempt state common-law claims unless the agency clearly and manifestly indicates an intent to forbid all state regulation in the area. NHTSA's decision not to require passenger seatbelts in motorcoaches did not express such an intent, so the jury's seatbelt verdict was not preempted.
2. FMVSS 205 is a minimum safety standard and does not preempt a state-law finding that a manufacturer should have selected laminated glass rather than another permitted glazing material.
3. Central Texas was a settling person under the applicable version of Texas Civil Practice and Remedies Code section 33.011(5), and the trial court erred by refusing to submit Central Texas's proportionate responsibility to the jury.

Questions Presented

1. Whether federal motor-vehicle safety regulations preempted the jury's common-law finding that the motorcoach should have included passenger seatbelts when federal regulations were silent on passenger seatbelts.
2. Whether FMVSS 205 preempted the jury's finding that the motorcoach should have used laminated rather than tempered glass when the federal standard permitted both materials.
3. Whether a debtor and its insurer participating in a bankruptcy-court plan that allocated insurance proceeds among claimants were settling persons under the applicable version of Texas Civil Practice and Remedies Code Chapter 33.

Disposition

affirmed