Federal Motor Vehicle Safety Standard (FMVSS) 208, promulgated by the U.S. Department of Transportation (DOT), required auto manufacturers to equip 10 percent of their 1987 vehicles with passive restraints, such as air bags. Through the standard, the DOT sought to encourage both the incorporation of passive restraint systems into automobiles and the passage of state mandatory seat belt laws, which was a factor in determing whether the passive restraint requirements became permanent. In 1992, despite wearing shoulder and lap belts, Alexis Geier was injured when she crashed her 1987 Honda Accord. Geier and her parents sued American Honda under a state common law negligence theory for failing to include a driver’s side air bag. Should the Geiers’ suit be allowed to move forward? [Geier v. American Honda Motor Co., 529 U.S. 861 (2000).]