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Administrative Law Keyed to Popper
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) beginning with large cars in model year 1982 and extending to all cars by 1984. The standard was upheld by the Court of Appeals and survived congressional scrutiny. The automobile industry began preparing to comply with the standard. However, in 1981, after a change in presidential administration, NHTSA rescinded the passive restraint requirement. The agency justified this decision by stating that it could no longer reliably predict significant safety benefits from the standard because manufacturers planned to install detachable automatic seatbelts in 99% of new cars rather than the expected mix of airbags (60%) and automatic belts (40%). NHTSA argued that these detachable belts would not increase seatbelt usage significantly and thus would not justify the approximately $1 billion implementation cost. The agency did not consider requiring airbags only or non-detachable belts as alternatives to rescinding the entire standard.
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