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Legislation and Regulation Keyed to Manning, 5th Ed.
Motor Vehicle Manufacturers’ Association v. State Farm Mutual Automobile Insurance Co.
Citation:
463 U.S. 29 (1983)Facts
In 1977, the Department of Transportation issued Modified Standard 208, which required automobile manufacturers to equip their vehicles with passive restraints (either airbags or automatic seatbelts) phased in between 1982 and 1984. This standard was upheld by the Court of Appeals and survived congressional scrutiny. The automobile industry began preparations to comply with the standard. However, in 1981, after a change in presidential administration, NHTSA rescinded the passive restraint requirement. The agency justified this decision by claiming that it could no longer reliably predict significant safety benefits from the standard because manufacturers planned to install easily detachable automatic seatbelts in 99% of new cars rather than airbags. NHTSA argued that these detachable belts would not increase seatbelt usage and therefore would not justify the approximately $1 billion implementation cost.
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