The head pose of a motor vehicle driver with respect to a vehicle frame of reference is assessed with a relative motion sensor positioned rearward of the driver's head, such as in or on the headrest of the driver's seat. The relative motion sensor detects changes in the position of the driver's head, and the detected changes are used to determine the driver's head pose, and specifically, whether the head pose is forward-looking (i.e., with the driver paying attention to the forward field-of-view) or non-forward-looking. The determined head pose is assumed to be initially forward-looking, and is thereafter biased toward forward-looking whenever driver behavior characteristic of a forward-looking head pose is recognized.