Motor Vehicle Manufacturers' Association v. State Farm Mutual Automobile Insurance Co.

463 U.S. 29 (1983)


The National Traffic and Motor Vehicle Safety Act of 1966 directed the Secretary of Transportation to issue motor vehicle safety standards under 15 U.S.C. Section 1392(a); 'shall be practicable, shall meet the need for motor vehicle safety, and shall be stated in objective terms.' In 1967, the Department issued standard 208 that simply required the installation of seatbelts in automobiles. In 1969, a standard was proposed for requiring the installation of passive restraints. That standard was amended in 1972 to require full passive protection for all front seat occupants of vehicles manufactured after 1975. In the interim vehicles built from August 1973 to August 1975 were to carry either passive or lap and shoulder belts coupled with an ignition interlock that would prevent starting the vehicle if the belts were not connected. The ignition interlock was highly unpopular and led Congress to amend the Act to prohibit a motor vehicle safety standard from requiring or permitting compliance by means of an ignition interlock or a continuous buzzer. Eventually, a new mandatory passive restraint regulation was issued that mandated the phasing in of passive restraints; airbags and passive belts. However, because of economic difficulties, the passive restraint requirement was rescinded in 1981. The NHTSA maintained that it was no longer able to find that the automatic restraint requirement would produce significant safety benefits. This was based on the reality that auto manufacturers were not going to install airbags and that the passive restraints could be detached easily. State Farm Mutual Automobile Insurance Co. (P) and the National Association of Independent Insurers filed petitions for review of NHTSA's rescission of the passive restraint Standard. The Court of Appeals for the District of Columbia Circuit held that the agency's rescission of the passive restraint requirement was arbitrary and capricious.