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Legislative Process Keyed to Bressman, 4th Ed.
Motor Vehicle Manufacturers’ Association v. State Farm Mutual Automobile Insurance Co.
Citation:
463 U.S. 29 (1983)Facts
In 1977, the Department of Transportation issued Modified Standard 208, which required automobile manufacturers to equip new cars 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 agency initially assumed that manufacturers would install airbags in 60% of new cars and automatic seatbelts in 40%. By 1981, however, it became apparent that manufacturers planned to install automatic seatbelts in approximately 99% of new cars, and that these belts would be detachable. In 1981, under a new administration, NHTSA rescinded the passive restraint requirement, concluding that it could no longer reliably predict that the requirement would produce significant safety benefits. The agency believed that detachable automatic belts would not significantly increase seatbelt usage and that the costs of implementation (approximately $1 billion) were not justified given the uncertain benefits. Insurance companies challenged this rescission, arguing that it was arbitrary and capricious.
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