Motor Vehicles Manufacturers Ass'n v. State Farm Mutual Automobile Insurance Co.

Motor Vehicle Manufacturers Association v. State Farm
Supreme Court of the United States
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
Chief Justice Warren E. Burger Associate Justices William J. Brennan Jr. · Byron White Thurgood Marshall · Harry Blackmun Lewis F. Powell Jr. · William Rehnquist John P. Stevens · Sandra Day O'Connor
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
General Rulemaking Notice of proposed rulemaking Adjudication Administrative law judge Code of Federal Regulations Federal Register
Statutory framework Administrative Procedure Act Freedom of Information Act National Environmental Policy Act Government in the Sunshine Act National Emergencies Act Inspector General Act Regulatory Flexibility Act Paperwork Reduction Act Unfunded Mandates Reform Act Congressional Review Act Federal Vacancies Reform Act
Regulatory coordination Office of Information and Regulatory Affairs Administrative Conference Executive orders Cost–benefit analysis (Executive Order 12866)
Judicial review of agency action Arbitrary and capricious State Farm Chevron deference Auer deference Loper Bright Committed to agency discretion Due process Londoner Bi-Metallic Goldberg Mathews Exhaustion Major questions Nationwide injunction Ripeness Abbott Labs Standing Lujan
Separation of powers Appointments Clause Freytag Noel Canning Congressional oversight Authorization Organic statute Appropriation Hearings Senate confirmation Independent agencies Humphrey's Executor Seila Law Unitary executive theory Legislative veto Chadha Nondelegation
Regulated fields (and agencies) Antitrust and competition FTC CPSC CFPB Banking Treasury OCC FDIC FRB Communication FCC Energy DOE FERC Environment EPA FWS Food FDA CDC Health care HHS Immigration DHS EOIR Labor DOL NLRB Patent/trademark PTO Securities SEC CFTC Taxation IRS TC Trade DOC ITC Transportation DOT STB NTSB Social Security SSA
Related topics Constitutional law Statutory interpretation
v t e

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.