In Geier v. American Honda Motor Co., 529 U.S. 861, 146 L. Ed. 2d 914, 120 S. Ct. 1913 (2000), the plaintiffs claimed that a passenger-car manufacturer was liable because it did not equip its 1987 vehicles with airbags. At the time, Standard 208 required car manufacturers to equip some, but not all, 1987 vehicles with passive restraints. The Supreme Court construed the Safety Act's preemption clause and saving clause together, unanimously concluding that the Safety Act does not expressly preempt "nonidentical state standards established in tort actions covering the same aspect of performance as an applicable federal standard." Geier, 529 U.S. at 868; see also Geier, 529 U.S. at 898 (Stevens, J., dissenting). But the Supreme Court also held that Standard 208 impliedly preempted the Geier plaintiffs' claims because those common-law claims conflicted with Standard 208. The Court observed that preemption based on conflict is different from an agency's express statement about preemptive intent because conflict preemption turns on identifying an actual conflict and not on an express statement. Geier, 529 U.S. at 884; see also English v. General Elec. Co., 496 U.S. 72, 78-79, 110 L. Ed. 2d 65, 110 S. Ct. 2270 (1990). Additionally, the Court noted that while preemption fundamentally is a question of congressional intent, courts traditionally distinguish between express and implied preemptive intent and treat conflict preemption as implied preemption. Geier, 529 U.S. at 884; see also Freightliner Corp. v. Myrick, 514 U.S. 280, 287, 131 L. Ed. 2d 385, 115 S. Ct. 1483 (1995); English, 496 U.S. at 78-79.