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Administrative Law Keyed to Seamon
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 new cars with passive restraints (either airbags or automatic seatbelts) phased in between 1982-1984. The standard was upheld by courts and survived congressional review. By 1981, it became apparent that manufacturers planned to comply primarily by installing detachable automatic seatbelts rather than airbags. In 1981, citing changed economic circumstances and concerns about the effectiveness of detachable belts, NHTSA rescinded the passive restraint requirement entirely. The agency concluded that because the detachable belts could be left detached permanently, they would not significantly increase seatbelt usage and therefore would not produce sufficient safety benefits to justify their cost. NHTSA did not consider requiring airbags only or non-detachable automatic belts as alternatives to rescinding the entire standard.
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