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Statutes and the Creation of Public Policy Keyed to Eskridge, 7th Ed.
Motor Vehicle Manufacturers’ Association v. State Farm Mutual Automobile Insurance Co.
Citation:
463 U.S. 29 (1983)Facts
The National Highway Traffic Safety Administration developed Modified Standard 208 in 1977, requiring passive restraint systems in automobiles to reduce traffic fatalities and injuries. The Standard allowed manufacturers to comply by installing either airbags or automatic seatbelts. By 1981, automobile manufacturers indicated they would install detachable automatic seatbelts in approximately 99% of new cars rather than airbags. NHTSA concluded that detachable belts could be easily disconnected and left permanently detached, requiring the same affirmative action as manual belts and thus providing minimal safety benefits. Based on this conclusion and concerns about the $1 billion implementation cost without adequate safety assurance, NHTSA rescinded the entire passive restraint requirement through Notice 25, rather than considering alternatives such as requiring airbags only or non-detachable automatic belts.
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