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Administrative Law Keyed to Funk
Motor Vehicle Manufacturers’ Association v. State Farm Mutual Automobile Insurance Co.
Citation:
463 U.S. 29 (1983)Facts
In 1977, the National Highway Traffic Safety Administration (NHTSA) issued Modified Standard 208, which required automobile manufacturers to equip new cars with passive restraint systems—either airbags or automatic seatbelts—by model year 1984. The agency estimated that this requirement would prevent approximately 12,000 deaths and over 100,000 serious injuries annually. In 1981, following a change in presidential administration, NHTSA rescinded the passive restraint requirement. The agency justified this rescission by arguing that automobile manufacturers planned to comply primarily with detachable automatic seatbelts rather than airbags, and that consumers would likely detach these belts, resulting in minimal safety benefits that did not justify the costs. NHTSA did not consider requiring airbags as an alternative to rescinding the entire standard, nor did it adequately analyze the potential effectiveness of non-detachable automatic belts.
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