(dissenting). I believe the seat belt statute was intended by the Legislature to apply in products liability actions and that the application of the statute in such actions creates no Title-Object Clause violation. Therefore, I disagree with Justice Weaver’s opinion that would hold that the Title-Object Clause prohibits the application of the seat belt statute in a products liability case. I also disagree with Justice Boyle’s opinion, which states that the language of the seat belt statute indicates it was not intended by the Legislature to apply in products liability actions.
I. TITLE-OBJECT CLAUSE
I do not agree that the constitutional principles embodied in the Title-Object Clause prohibit the seat belt statute from applying in products liability cases. Justice Weaver’s opinion would hold “[a]s a matter of statutory interpretation, we must not, and under constitutional principles we cannot, apply statutes in the motor vehicle code to cases involving the civil liability of manufacturers.” Ante at 591. The opinion reaches this conclusion because the title of the act includes “liability of owners and operators,” but does not explicitly mention the liability of manufacturers. I find this reasoning to be flawed.
The Title-Object Clause provides:
*601No law shall embrace more than one object, which shall be expressed in its title. No bill shall be altered or amended on its passage through either house so as to change its original purpose as determined by its total content and not alone by its title. [Const 1963, art 4, § 24.]
The purpose of the Title-Object Clause has been “ ‘many times discussed and passed on by this [C]ourt.’ ’1 The clause insures that adequate notice will be given of the possible effects of a law enacted by the Legislature.
It may be said at the outsét that the provision is designed to serve two purposes. First, to prevent action by the legislature without receiving the concurrence therein of the requisite number of members by — “bringing together into one bill subjects diverse in their nature, and having no necessary connection, with a view to combine in their favor the advocates of all.” — [W]hat is commonly spoken of as logrolling in legislation — -and also to prevent clauses being— “inserted in bills of which the titles gave no intimation, and their passage secured through legislative bodies whose members were not generally aware of their intention and effect.” People [ex rel Drake] v Mahaney, 13 Mich 481, 494 [(1865)]. [A]nd, second, to “challenge the attention” of those affected by the act to its provisions. People v Wohlford, 226 Mich 166, 168 [197 NW 558 (1924)][2]
Justice Weaver’s opinion holds that the seat belt statute is incongruous in a products liability action. Applying the act in such an action would result in the act exceeding the scope of its title in violation of the *602Title-Object Clause. The opinion relies on Maki v City of East Tawas,3 to find the application of the seat belt statute in products liability actions to be unconstitutional. Maki stands for the rule that the Legislature may limit the permissible scope of an act by limiting its title. At issue in Maki was a statute that abolished governmental liability for torts, but whose title included the object of abolishing governmental liability only for negligence.
Liability for torts is much broader than liability for negligence. We held in Maki that the specific mention of negligence in an act’s title limits the constitutional scope of the act. The Legislature has the right to limit an act in its title or, conversely, to provide for broader application. 385 Mich 157. It limited the scope of the act reviewed in Maki by specifying in the title that it would apply to immunity for negligence.
Justice Weaver has concluded that the Legislature limited the parties whose liability could be affected by the act. She has applied the rule of statutory construction that provides that mention of one thing, but not another, implies exclusion of the other. She maintains that the Legislature limited the parties affected by mentioning the liability of owners and drivers, but not of manufacturers. I find the conclusion unwarranted.
The mere fact that the statute mentions the liability of owners and drivers but does not mention manufacturers is inconclusive. It does not evidence a legislative intent to limit the act to owners and drivers in the way the governmental immunity statute’s title pro*603vision limited that act’s scope in Maki. The reason that the title of the statute mentions owners and drivers is that its purpose is to create liability for owners and drivers.4 The seat belt statute does not create liability for manufacturers. There is a vast difference between creating liability and affecting liability, which is what the seat belt statute does.
The seat belt statute affects the liability of manufacturers, but does not mention manufacturers in its title. It does not follow that its application to the civil liability of manufacturers is unconstitutional. If that were the case, would it not be unconstitutional to apply the motor vehicle code to the civil liability of pedestrians,5 bicyclists,6 passengers,7 and the state?8 *604The title of the motor vehicle code does not mention them any more than it mentions manufacturers.9
Although the Legislature did not name manufacturers in the title to the motor vehicle code, the code has been applied directly to manufacturers for many years. See, for example, 1915 PA 302(16). Several of the code’s provisions create minimum standards for automobile equipment.10 Was not the Legislature attempting to make the manufacturers of that equipment responsible for compliance? Would a manufacturer building a vehicle not meeting those standards be able to sell it, despite the resulting violations, because the motor vehicle code does not apply to it?
*605I believe that it is incorrect to conclude on a broad basis that the motor vehicle code may not constitutionally apply to manufacturers.11 The title of the motor vehicle code is not as restrictive as the title of the statute found unconstitutional in Maki. There, the Legislature specifically limited the scope of the act to the immunity of the government from negligence liability. Here, the Legislature has not restricted the title to apply only to the safety equipment manufacturers are required to include in vehicles they build. The basis of the decision in Maki was that the Legislature had limited the scope of the act. By contrast, the Legislature has not limited the application of the motor vehicle code as it applies to manufacturers. Therefore, I conclude that the title does not exclude application to manufacturers.
The fundamental disagreement I have with Justice Weaver’s opinion is that it reflects a belief that the seat belt statute, if applied to manufacturers, created liability for them at the time it was enacted. This is incorrect. While the seat belt statute might increase the liability of a manufacturer today, at the time it became law, the statute lessened the liability of manufacturers. As a result of this misapprehension, Justice Weaver’s concurring opinion takes a narrow view of the code’s title provisions by concentrating on the civil liability provision. It ignores other portions of *606the title that easily justify the application of the seat belt statute in the products liability context.12
One purpose of the Title-Object Clause is to provide notice of a law’s scope to those enacting it. Hence, our attention should go to what the Legislature knew at the time it considered enacting a law, and what the law was intended to accomplish when enacted. Not relevant is the state of the law when judicially reviewed. Therefore, to determine properly whether a title-object violation has occurred, we examine the state of the law at the time an act was adopted.13
On the date that the seat belt statute became law, it did not create liability for manufacturers. Instead, it limited the recovery of plaintiffs who failed to comply with its provisions. The Legislature enacted the seat belt statute in 1985, creating a standard of care for drivers and front seat passengers by requiring them to *607buckle their seat belts. It provided a penalty for violation of the standard in the form of a civil infraction. To further encourage seat belt usage, the act provided the added penalty of allowing the admission at trial of evidence of a plaintiffs failure to properly use a seat belt. The Legislature limited the penalty to a reduction in damages of five percent.
As Justice Weaver points out, evidence of seat belt nonuse was not admissible in any action, whether it was for products liability or for negligence, until the seat belt act became law. The reason is that contributory negligence was the law until this Court’s decision in Placek v Sterling Heights.14 When we adopted comparative negligence, contributory negligence was seen as harsh and unjust because it had acted as an absolute bar to plaintiffs who were only slightly at fault. Evidence of seat belt nonuse had not been admissible to defeat contributory negligence. Romankewiz v Black, 16 Mich App 119; 167 NW2d 606 (1969).
In a negligence action, seat belt nonuse was not admissible under comparative negligence, either, before the seat belt statute was enacted, even though it was no longer a complete bar to recovery. Likewise, seat belt nonuse was inadmissible in products liability actions arising during the years between the enactment of the products liability statute that adopted comparative negligence and the seat belt statute.15 In effect, when the Legislature enacted the seat belt statute, it replaced a zero-percent reduction under the common law with a five-percent reduction for viola*608tion of the statute. The five-percent reduction in damages was a penalty specifically authorized by the code’s title. Therefore, when the Legislature enacted the seat belt statute, it was intended as a punishment for drivers and front seat passengers. It was not a windfall for plaintiffs, as the concurring opinions would have us believe. It is exactly the type of provision specifically authorized in the title of the act.16
I conclude that the Title-Object Clause does not prohibit the direct application of the motor vehicle code in cases involving the liability of a manufacturer. The issue, then, is how broadly the Legislature intended application to be of the punishment contained in the seat belt statute.
H. STATUTORY ANALYSIS
The Court of Appeals held that the language of the seat belt statute indicates that it was not intended to apply in products liability actions. 219 Mich App 500; 556 NW2d 528 (1996). The seat belt statute provides:
Failure to wear a safety belt in violation of this section may be considered evidence of negligence and may reduce the recovery for damages arising out of the ownership, maintenance, or operation of a motor vehicle. However, *609such negligence shall not reduce the recovery for damages by more than 5%. [MCL 257.710e(5); MSA 9.2410(5)(5) (emphasis added).[117]
The Court of Appeals held that a products liability action does not “arise out of the ‘ownership, maintenance, or operation of a motor vehicle.’ ” 219 Mich App 506. The Court based this conclusion on similar language in the no-fault act that this Court has held does not abolish the liability of a manufacturer. The no-fault act provides in pertinent part:
Notwithstanding any other provision of law, tort liability arising from the ownership, maintenance, or use within this state of a motor vehicle ... is abolished .... [MCL 500.3135(3); MSA 24.13135(3) (emphasis added).]
As the Court of Appeals noted, we have held that the no-fault act did not abolish the products liability of a manufacturer:
Only persons who own, maintain or use motor vehicles can be subject to tort liability for injuries or damage caused by the ownership, maintenance or use of a motor vehicle. The non-motorist tortfeasor cannot be subject to tort liability for injuries or damage caused by the ownership, maintenance or use of a motor vehicle. [Citizens Ins Co of America v Tuttle, 411 Mich 536, 545; 309 NW2d 174 (1981).]
At first glance, a similarity in language of the two statutes is clear. However, the similarity does not indicate that the Legislature intended identical results under the statutes. A comparison of the two reveals that they are not identical, and the difference in the *610language that the Legislature chose to include in each is decisive.
The no-fault act refers to “liability arising from the ownership, maintenance, or use ... of a motor vehicle.” The seat belt law refers to “damages arising out of the ownership, maintenance, or operation of a motor vehicle.” The liability arising from a cause and the damages arising from it, are, by definition, not identical. It is entirely possible that someone incurs damages from the operation of a motor vehicle when no liability has arisen from the ownership, maintenance, or operation of the vehicle.18
I take issue with Justice Boyle’s suggestion that my interpretation of the seat belt law would expand it beyond its limitations and “trump” recent legislative enactments in the no-fault act. The basis of Justice Boyle’s entire analysis seems to be the belief that the seat belt statute applies only under MCL 500.3135; MSA 24.13135. Ante at 597. That the Legislature amended a statute that may conflict with the seat belt statute, in an area we agree both were intended to apply, does not call into question my analysis.
It may be that the Legislature intended this recent enactment to “trump” the seat belt statute, and perhaps Justice Boyle’s dicta to that effect will turn out to be accurate. It is incorrect, however, to suggest that something has gone awry if the seat belt statute should “trump” the current system of apportionment of damages.
*611This is exactly what the seat belt rules have always done, whether they were statutory or common law. At common law, seat belt evidence was inadmissible to prove contributory negligence. It was inadmissible, even though its exclusion was inconsistent with the fault apportionment system that completely denied recovery to a plaintiff whose negligence to any degree caused the plaintiffs injuries. It also “trumps” a pure comparative negligence system, like the one previously in effect.
A five-percent cap is no more inconsistent with modified comparative negligence than it was with contributory negligence or pure comparative negligence. In each case, it interferes with a jury determination of fault. I express no opinion on the interaction between the two current statutes. However, it seems to me that the fact that the seat belt statute might “trump” modified comparative negligence is not as inconsistent as Justice Boyle would suggest.
As indicated before, I believe Justice Boyle’s opinion suffers from the same analytical flaw as Justice Weaver’s: it attempts to determine legislative intent on the basis of the state of the law today, rather than at the time the law was enacted. The opinion concludes by stating:
To conclude that the Legislature intended a broad-based preclusion of the comparative negligence principle we adopted in Placek ... by its foray into safety belt usage, ascribes an intent not evident from the language of the statute or its histoiy- [Ante at 599-600.]
If the Legislature did not intend to preclude the application of pure comparative negligence when it adopted the seat belt statute, then what did it intend?
*612I believe the Legislature intended the broad-based penalty of the seat belt statute to be applicable in any action involving a motor vehicle accident. What Justice Boyle loses sight of is that, at the time the statute was enacted, it was a punishment for plaintiffs who failed to wear their seat belts. The punishment is proper under the title of the motor vehicle code, which provides for regulations on the use of the road and, also, for statutes which punish their violation. The seat belt statute was designed to encourage drivers to wear their seat belts. The Legislature must have concluded that limiting recovery for those who fail to wear seat belts would further its goal. If this is true, the more actions in which a plaintiff’s recovery was limited, the more effective the act would be. The fact that the state of the law has changed does not retroactively alter the Legislature’s intent in passing the seat belt statute.
m. NEGLIGENCE PER SE
The concurring opinions admit that their analyses prevent the direct application of the motor vehicle code to the liability of manufacturers. Although they cannot agree on a rationale for this conclusion, they do agree that the availability of negligence per se limits the harm done. I believe that application of the motor vehicle code in products liability actions through negligence per se, alone, is inconsistent with legislative intent.
Negligence per se allows the use of a violation of a statutory standard of care as evidence of negligence. Not all statutes content themselves with merely providing standards of care. Some limit the penalty, as the seat belt statute does, to less than that arrived at *613under negligence per se, while others expand liability for violations well beyond it.
The seat belt statute provides for the admission of otherwise excluded evidence and limits its use. If the Legislature had the power to enact such a statute, the opinion places that power in serious doubt.
After today, the Legislature may not enact a statute of similarly limited effect without running the risk that the Court will apply it somewhere else and ignore the limit. It is not clear that, in 1985, the Legislature would have enacted a statute that allowed unlimited use of seat belt evidence, or allowed a massive reduction in damages for nonuse. What is clear, however, is that it did not. What it enacted was a standard of care that carried with it a limited penalty for its violation.
The concurring opinions would allow use of the evidence the Legislature made admissible in actions to which, they argue, the statute does not directly apply. Moreover, they would allow it without the limitations the Legislature placed on its admission. Under their analysis, the seat belt statute was intended to apply in negligence actions, where its application is limited by its own terms. Yet, the opinions state, in actions in which the statute was not intended to apply, the doctrine of negligence per se allows the evidence, without the statute’s limitations.
Assume the Legislature had the power to create the standard of care and to provide that violations of it may be used as evidence of negligence. It would follow, then, that the Legislature had the power to limit the standard’s application.
Moreover, unlike the negligence per se application of the seat belt statute, which expands its effect *614beyond its inherent limitation, some motor vehicle code provisions will be unnecessarily limited under negligence per se. In this way, the concurring opinions frustrate the Legislature’s intent and limit its power.
One example of a statute that would be unnecessarily limited by today’s concurring opinions is MCL 257.719(1); MSA 9.2419(1). It states:
A vehicle unloaded or with load shall not exceed a height of 13 feet 6 inches. The owner of a vehicle that collides with a lawfully established bridge or viaduct is liable for aU damage and injury resulting from a collision caused by the height of the vehicle, whether the clearance of the bridge or viaduct is posted or not. [Emphasis added.]
The Court of Appeals recently held that, although a violation of the statute would establish negligence per se, the statute provides for “absolute liability.” Dep’t of Transportation v Christensen, 229 Mich App 417; 581 NW2d 807 (1998). The Court reversed the trial court’s decision that the driver’s “liability was subject to the principles of comparative fault, joint and several liability, and proximate cause.”
Had the defendant been General Motors Corporation instead of MDOT, gm would not have had the benefit of this absolute liability statute. Instead, the concurring opinions’ conclusion that the motor vehicle code does not affect the liability of a manufacturer means that the standard of care may be applied through negligence per se. However, the absolute liability provision will not apply because the statute cannot be used directly in a products liability action.
The concurring opinions will have a much broader effect than they intend because they render some par*615ties, other than manufacturers, no longer subject to motor vehicle code liability. Assume that Justice Weaver is correct in finding that the motor vehicle code does not apply to manufacturers because it does not specifically mention that it will govern their liability. How, then, is the liability of the state governed by the act? While there are provisions in the title for the establishment of state agencies and for prescribing their “powers and duties,” the title makes no mention of establishing the liability of a state agency.
The plaintiff in Christensen, supra, bore the burden of pleading in avoidance of governmental immunity and also of proving his negligence action.19 There, the Court of Appeals applied provisions from the motor vehicle code to the liability of an agency of state government, for which its title does not specifically create liability. It seems to me that application of the statute to the state is entirely proper. However, it would seem to violate the rules proposed by the concurring opinions today.
IV. CONCLUSION
In Lowe we found that evidence of nonuse of a seat belt was admissible against rear seat passengers in a products liability action. We noted that the inclusion of the evidence might be inconsistent with the seat belt statute. However, we concluded that the inconsistency was for the Legislature to remedy.
*616The issue presented does not involve statutory construction .... While we are cognizant of the potential argument that the effect of the five-percent limitation could lead, potentially and perhaps anomalously, to the irrational result of protecting the recoveries of individuals whose failure to use seat belts was in violation of the statute, while not protecting the recoveries of those whose failure to use seat belts was not in violation of it, we are compelled to conclude that the effect is essentially a legislative concern. [Lowe v Estate Motors Ltd, 428 Mich 439, 469; 410 NW2d 706 (1987).]
In the years since Lowe, the Legislature has not amended or repealed the seat belt statute. Therefore, it is still the law. The state of the law has changed dramatically since the seat belt statute was enacted. However, that is no reason to ignore the state of the law at the time of the statute’s passage and the reasons that impelled it. The fact that the landscape of the law is different today does not mean that there is a title-object problem. Nor does it mean that, as a matter of statutory interpretation, the seat belt statute cannot apply.
The reason the seat belt statute now favors plaintiffs over defendants is that this Court has ruled that seat belt nonuse is admissible in products liability actions under the common law. Perhaps this ruling creates a conflict between acts of the Legislature, or between its acts and the decisions of this Court. The solution to the conflict, if one exists, is not to expand the purpose of the Title-Object Clause or, retroactively, to alter the Legislature’s intent.
Therefore, I respectfully dissent.
Cavanagh, J., concurred with Kelly, J.Advisory Opinion re Constitutionality of 1972 PA 294, 389 Mich 441, 468; 208 NW2d 469 (1973), quoting Commerce-Guardian Trust & Savings Bank v Michigan, 228 Mich 316; 200 NW 267 (1924), and Rohan v Detroit Racing Ass’n, 314 Mich 326, 355-356; 22 NW2d 433 (1946).
228 Mich 330-331. See Maki v City of East Tawas, 385 Mich 151, 157-158; 188 NW2d 593 (1971).
385 Mich 151; 188 NW2d 593 (1971).
The motor vehicle code defines the liability of a driver:
The owner of a motor vehicle is liable for an injury caused by the negligent operation of the motor vehicle whether the negligence consists of a violation of a statute of this state or the ordinary care standard required by common law. The owner is not liable unless the motor vehicle is being driven with his or her express or implied consent or knowledge. [MCL 257.401(1); MSA 9.2101(1).]
The code further provides for the liability of drivers through the enactment of standards of care, and creates penalties for violations of those duties. See, for example, MCL 257.402; MSA 9.2102. See, generally, MCL 257.601-257.680; MSA 9.2301-9.2380.
Jacobson v Carlson, 302 Mich 448; 4 NW2d 721 (1942). (There is no title-object violation where a provision of the motor vehicle code contains a standard of care for pedestrians.)
MCL 257.657; MSA 9.2357. (“Every person riding a bicycle or moped upon a roadway shall be granted all of the rights and shall be subject to all of the duties applicable to the driver of a vehicle by this chapter ----”)
MCL 257.677(2); MSA 9.2377(2). (“A passenger in a vehicle . . . shall not ride in a position as to interfere with the driver’s or operator’s view ahead or to the sides. . . .”)
See, for example, Dep’t of Transportation v Christensen, 229 Mich App 417; 581 NW2d 807 (1998), in which the Court of Appeals held that MCL 257.719(1); MSA 9.2419(1) applied to the benefit of the Department *604of Transportation. The Court held that the statute created “absolute liability” for a truck driver whose truck hits an overpass.
Justice Weaver responds to this argument by pointing to examples of title provisions that are broad enough to justify application of the motor vehicle code to these parties. While I agree that the code’s title is broad enough to encompass them, I find her attempt to dismiss this argument unconvincing. Justice Weaver would hold that the act cannot affect the civil liability of manufacturers because it does not mention manufacturers. Her response does not refute the argument that, under her rule, because the code’s title does not mention the state, it cannot constitutionally affect the liability of the state. The act at issue in Christensen, supra, MCL 257.719(1); MSA 9.2419(1), lessened the state’s liability, thereby affecting it. I believe Justice Weaver’s analysis would make the application of the act to the liability of the state unconstitutional, an indication that her analysis is incorrect. See part m.
Specifically, see MCL 257.710b; MSA 9.2410(2), which provides:
A private passenger vehicle manufactured after January 1, 1965 shall not be offered for sale in this state unless the vehicle is equipped with safety belts for the use of the driver and 1 other front seat passenger.
See also MCL 257.685; MSA 9.2385, which requires headlamps and governs their placement and power; MCL 257.686; MSA 9.2386, which requires rear lamps; MCL 257.689; MSA 9.2389, MCL 257.690-257.691; MSA 9.2390-9.2391, MCL 257.696-257.697; MSA 9.2396-9.2397, MCL 257.699-257.701; MSA 9.2399-9.2401, and MCL 257.705-257.707; MSA 9.2405-9.2407.
I conclude that Justice Weaver would adopt a broad preclusion of the motor vehicle code’s application to manufacturers. The conclusion arises from her statement that the motor vehicle code cannot constitutionally apply to the manufacture of motor vehicles or the civil liability of manufacturers. See ante at 589. Without application to these two areas, I fail to see what application the code could have to a manufacturer.
For example, the title provides for “regulation and use of streets and highways; . . . penalties and sanctions for violation of this act; . . . [and] enforcement of this act . . . .” In fact, Justice Weaver relies on provisions like these to support the application of the code to other persons not specifically mentioned. See ante at 591, n 7.
This Court has discussed the proper application of the Title-Object Clause on a number of occasions, and “[w]e have often held that this constitutional stricture on statutory enactments was not a hollow formality.” 385 Mich 157. “ ‘However, in effectuating these purposes, the “one object” provision is to be construed reasonably and not in so narrow or technical a manner as to frustrate the legislative intent.’ ” Livonia v Dep’t of Social Services, 423 Mich 466, 497; 378 NW2d 402 (1985), quoting Greentrees v Pignatiello, 123 Mich App 767, 771; 333 NW2d 350 (1983) (citations omitted). “Legislation, if it has a primary object, is not invalid because it embraces more than 1 means of attaining its primary object.” Local No 1644, AFSC&ME, AFL-CIO v Oakwood Hosp Corp, 367 Mich 79, 91; 116 NW2d 314 (1962). Moreover, “[a]n act may contain all matters germane to its object” and any provisions which “ ‘directly relate to, carry out and implement the principal object.’ ” 423 Mich 497.
If there is a constitutional infirmity in the seat belt statute, it is not to be found in the title.
405 Mich 638; 275 NW2d 511 (1979).
See Ullery v Sobie, 196 Mich App 76; 492 NW2d 739 (1992) (per curiam opinion joined by Marilyn Kelly, P.J.); Thompson v Fitzpatrick, 199 Mich App 5; 501 NW2d 172 (1992).
One example along these lines is MCL 257.402(1); MSA 9.2102(1), which states:
In any action, in any court in this state when it is shown by competent evidence, that a vehicle traveling in a certain direction, overtook and struck the rear end of another vehicle proceeding in the same direction . . . the driver or operator of such first mentioned vehicle shall be deemed prima facie guilty of negligence. [Emphasis added.]
The controlling language in this statute is very broad. It demonstrates the Legislature’s intent to create a statutory duty of care and a punishment for its breach that applies outside the motor vehicle code.
The seat belt statute now appears at MCL 257.710e(6); MSA 9.2410(5)(6).
Justice Boyle purports to find a distinction between the statutory requirement to wear a seat belt and the statutory punishment for violating the requirement. However, I do not agree that the statutory requirement can be applied through negligence per se, without the damages cap placed on it by the Legislature.
The governmental tort liability act, MCL 691.1407; MSA 3.996(107), waives the state’s immunity from liability in certain limited areas. However, in order to successfully bring suit against an agency of the state, one has to plead in avoidance of governmental immunity and prove an underlying cause of action. See Canon v Thumudo, 430 Mich 326; 422 NW2d 688 (1988).