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Administrative Law Keyed to Cass
Motor Vehicle Manufacturers’ Association v. State Farm Mutual Automobile Insurance Co.
Citation:
463 U.S. 29 (1983)Facts
The National Traffic and Motor Vehicle Safety Act of 1966 directed the Secretary of Transportation to issue motor vehicle safety standards to reduce traffic accidents and deaths. NHTSA developed Modified Standard 208 requiring passive restraints (airbags or automatic seatbelts) to be phased into vehicles beginning in 1982. The agency estimated passive restraints could prevent approximately 12,000 deaths and over 100,000 serious injuries annually. In 1981, Secretary Andrew Lewis reopened rulemaking due to changed economic circumstances and automobile industry difficulties. NHTSA discovered that manufacturers planned to install detachable automatic seatbelts in approximately 99% of new cars rather than the anticipated mix of 60% airbags and 40% automatic belts. The agency concluded that detachable belts could be easily disconnected and left that way permanently, requiring the same affirmative action as manual belts and therefore providing minimal safety benefits. NHTSA rescinded the entire passive restraint requirement, citing substantial uncertainty about safety benefits and concerns about adverse public reaction to expensive but ineffective regulation.
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