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Regulatory Law Keyed to Shapiro, 4th Ed.
Motor Vehicle Manufacturers’ Association v. State Farm Mutual Automobile Insurance Co.
Citation:
463 U.S. 29 (1983)Facts
In 1977, NHTSA issued Modified Standard 208, which required automobile manufacturers to equip new cars with passive restraints (either airbags or automatic seatbelts) phased in from 1982 to 1984. The standard was upheld by courts and survived congressional scrutiny. In 1981, under a new administration, NHTSA rescinded the requirement, citing changed circumstances. The agency determined that automobile manufacturers planned to install detachable automatic seatbelts in 99% of new cars rather than the expected mix of airbags (60%) and automatic seatbelts (40%). NHTSA concluded that these detachable belts would not significantly increase seatbelt usage and therefore would not produce sufficient safety benefits to justify the approximately $1 billion implementation cost. The agency did not consider requiring airbags as an alternative or mandating nondetachable automatic seatbelts.
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