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Legislation and Regulation Keyed to Eskridge, 1st Ed.
Motor Vehicle Manufacturers’ Association v. State Farm Mutual Automobile Insurance Co.
Citation:
463 U.S. 29 (1983)Facts
In 1977, NHTSA issued Modified Standard 208, which required automobile manufacturers to install passive restraints (either airbags or automatic seatbelts) in all new cars by model year 1984. The agency estimated that this requirement would save approximately 12,000 lives and prevent over 100,000 serious injuries annually. After a change in presidential administrations, NHTSA reopened the rulemaking in 1981 and ultimately rescinded the passive restraint requirement. The agency justified this decision by noting that automobile manufacturers planned to install detachable automatic seatbelts in 99% of new cars rather than the expected mix of airbags (60%) and automatic belts (40%). NHTSA concluded that these detachable belts would not significantly increase seatbelt usage because occupants could easily detach them and leave them detached. The agency also cited concerns about the cost of implementation (approximately $1 billion) and possible adverse public reaction to what it considered ineffective regulation.
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