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Administrative Law Keyed to Aman
Motor Vehicle Manufacturers’ Association v. State Farm Mutual Automobile Insurance Co.
Citation:
463 U.S. 29 (1983)Facts
In 1977, the Department of Transportation, through NHTSA, issued Modified Standard 208, which required automobile manufacturers to equip their vehicles with passive restraints (either airbags or automatic seatbelts) beginning with large cars in model year 1982 and extending to all cars by model year 1984. The automobile industry began preparing to comply with this standard. In 1981, following a change in presidential administration, NHTSA rescinded the passive restraint requirement. The agency justified this action by claiming that, contrary to its earlier assumptions, manufacturers planned to install detachable automatic seatbelts in 99% of new cars rather than airbags, and that these detachable belts would not significantly increase seatbelt usage rates. NHTSA concluded that the costs of implementing the standard (approximately $1 billion) were not justified given the uncertain safety benefits. The agency did not consider requiring airbags alone or non-detachable automatic seatbelts as alternatives to complete rescission.
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