Motor Vehicle Manufacturers Association v. State Farm | |
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Argued April 26, 1983 Decided June 24, 1983 | |
Full case name | Motor Vehicle Manufacturers Association of the United States, Inc., et al. v. State Farm Automobile Insurance Company et al; Consumer Alert, et al. v. State Farm Mutual Automobile Insurance Company et al.; United States Department of Transportation, et al. v. State Farm Mutual Automobile Insurance Company et al. |
Docket no. | 82-354-56 |
Citations | 463 U.S. 29 (more) 103 S. Ct. 2856; 77 L. Ed. 2d 443; 13 Envtl L. Rep. 20,672 |
Argument | Oral argument |
Case history | |
Prior | State Farm Mutual Automobile Insurance Co. v. Dept. of Transportation, 680 F.2d 206 (D.C. Cir. 1982); cert. granted, 459 U.S. 987 (1982). |
Holding | |
The standard of review for rescinding notice and comment rules is the same as that for enacting rules. The rescission was arbitrary and capricious for failing to consider the alternative of requiring airbags and dismissing too quickly the benefits of automatic seat belts. | |
Court membership | |
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Case opinions | |
Majority | White, joined by unanimous (Parts I-IV, V-A); Brennan, Marshall, Blackmun, Stevens (Part V-B, VI) |
Concur/dissent | Rehnquist, joined by Burger, Powell, O'Connor |
Laws applied | |
Administrative Procedure Act |
Administrative law of the United States |
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Motor Vehicle Manufacturers Association v. State Farm Mutual Automobile Insurance Co., 463 U.S. 29 (1983), commonly known in U.S. administrative law as State Farm, is a United States Supreme Court decision concerning regulations requiring passive restraints in cars. Decided in 1983, one year before Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., the Court found that the National Highway Traffic Safety Administration had not provided a "reasoned analysis" for rescinding regulations that required either airbags or automatic seat belts in new cars.[1]
It held that the arbitrary and capricious standard for reviewing agency action to enact regulations also applied to changing regulations. It held the rescinding the standard was arbitrary and capricious because the NHTSA did not provide evidence for the decision for two reasons: 1) The agency did not consider alternatives like requiring all cars to have airbags 2) The agency did not provide any evidence for its findings that automatic seat belts would not increase seat belt usage, even though the record evidence included surveys of drivers showing that seat belt usage more than doubled over manual seat belts.
The case is noteworthy not only for its effects on car safety but also in clarifying the Court's approach to reviewing agency actions under the Administrative Procedure Act.
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