Motor Vehicle Manufacturers Assoc. v. State Farm Mutual Automobile
Ins. Co. case brief summary
463 U.S. 29 (1983)
CASE FACTS
Under authority of the National Traffic and Motor Vehicle Safety Act of 1966 (Act), 15 U.S.C.S. § 1381 et seq., the National Highway Traffic Safety Administration (NHTSA) promulgated Standard 208 to require installation of seatbelts in all automobiles. Subsequently, the NHTSA promulgated rules to require passive restraint systems in new vehicles, but then rescinded the requirement on the basis that it was no longer able to find that the requirement would produce significant safety benefits. Respondent automobile insurers filed petitions for review of the NHTSA's rescission. The district court held that the NHTSA's rescission was arbitrary and capricious. Petitioners sought a writ of certiorari, which was granted.
DISCUSSION
The court vacated the judgment of the lower court and remanded the cases to the lower court with directions to remand the matter to the NHTSA for further consideration consistent with the court's opinion that the NHTSA failed to present an adequate basis and explanation for rescission, as required under the Administrative Procedure Act.
Recommended Supplements for Administrative Law Examples & Explanations: Administrative Law, Fourth Edition
Administrative Law and Process: In a Nutshell (Nutshell Series)
463 U.S. 29 (1983)
CASE SYNOPSIS
Certiorari was granted to the United
States Court of Appeals for the District of Columbia Circuit, in a
review filed by respondent automobile insurance companies contesting
the National Highway Traffic Safety Administration's (NHTSA)
rescission of a passive restraint safety standard for all new
automobiles as arbitrary and capricious under the informal rulemaking
procedures of the Administrative Procedure Act, 5 U.S.C.S. §
553.CASE FACTS
Under authority of the National Traffic and Motor Vehicle Safety Act of 1966 (Act), 15 U.S.C.S. § 1381 et seq., the National Highway Traffic Safety Administration (NHTSA) promulgated Standard 208 to require installation of seatbelts in all automobiles. Subsequently, the NHTSA promulgated rules to require passive restraint systems in new vehicles, but then rescinded the requirement on the basis that it was no longer able to find that the requirement would produce significant safety benefits. Respondent automobile insurers filed petitions for review of the NHTSA's rescission. The district court held that the NHTSA's rescission was arbitrary and capricious. Petitioners sought a writ of certiorari, which was granted.
DISCUSSION
- The court held that the NHTSA failed to present an adequate basis and explanation for rescinding the passive restraint requirement and required the NHTSA to either reconsider the restraint issue further, or amend Standard 208 to comply with the supporting analysis.
- The court held that under the "arbitrary and capricious" standard of judicial review, the NHTSA failed to provide clear and convincing reasons for its action to abandon the passive restraint system.
The court vacated the judgment of the lower court and remanded the cases to the lower court with directions to remand the matter to the NHTSA for further consideration consistent with the court's opinion that the NHTSA failed to present an adequate basis and explanation for rescission, as required under the Administrative Procedure Act.
Recommended Supplements for Administrative Law Examples & Explanations: Administrative Law, Fourth Edition
Administrative Law and Process: In a Nutshell (Nutshell Series)
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