MOTOR VEHICLE MANUFACTURERS' ASSOCIATION V. STATE FARM MUTUAL AUTOMOBILE INSURANCE CO.
463 U.S. 29 (1983)
NATURE OF THE CASE: This was a dispute over a requirement that new cars be equipped with
passive restraints and a challenge to NHTSA’s rescission of the passive restraint
requirement as being arbitrary and capricious.
FACTS: The National Traffic and Motor Vehicle Safety Act of 1966 directed the Secretary
of Transportation to issue motor vehicle safety standards under 15 U.S.C. Section 1392(a);
'shall be practicable, shall meet the need for motor vehicle safety, and shall be stated in
objective terms.' In 1967, the Department issued standard 208 that simply required the
installation of seatbelts in automobiles. In 1969, a standard was proposed for requiring the
installation of passive restraints. That standard was amended in 1972 to require full
passive protection for all front seat occupants of vehicles manufactured after 1975. In the
interim vehicles built from August 1973 to August 1975 were to carry either passive or lap
and shoulder belts coupled with an ignition interlock that would prevent starting the
vehicle if the belts were not connected. The ignition interlock was highly unpopular and led
Congress to amend the Act to prohibit a motor vehicle safety standard from requiring or
permitting compliance by means of an ignition interlock or a continuous buzzer. Eventually,
a new mandatory passive restraint regulation was issued that mandated the phasing in of
passive restraints; airbags and passive belts. However, because of economic difficulties the
passive restraint requirement was rescinded in 1981. The NHTSA maintained that it was no
longer able to find that the automatic restraint requirement would produce significant
safety benefits. This was based on the reality that auto manufacturers were not going to
install airbags and that the passive restraints could be detached easily. State Farm Mutual
Automobile Insurance Co. (P) and the National Association of Independent Insurers filed
petitions for review of NHTSA's rescission of the passive restraint Standard. The Court of
Appeals for the District of Columbia Circuit held that the agency's rescission of the
passive restraint requirement was arbitrary and capricious.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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