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 NEPA GSA NEA IGA RFA PRA UMRA CRA FVRA
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 Committed to agency discretion Due process Londoner Bi-Metallic Goldberg Mathews Exhaustion Major questions doctrine 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
Related areas of law (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), is a United States Supreme Court decision concerning regulations requiring passive restraints in cars. In it, the Court struck down an order by the National Highway Traffic Safety Administration rescinding regulations that required either airbags or automatic seat belts in new cars.^[1]

It held that the same arbitrary and capricious standard for reviewing agency actions applied to rescind regulations as that to enact regulations. It also held that the rescission of the rule requiring some sort of passive restraint was arbitrary and capricious because it failed to consider the alternative of requiring all cars to have airbags. Finally, it held that the agency had too quickly dismissed the safety benefits of automatic 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.