The National Highway Traffic Safety Administration (the administration) (defendant) was the organization responsible for issuing recalls of unsafe motor vehicles. Car manufacturers could also voluntarily issue recalls. In the 1980s, manufacturers began issuing voluntary recalls on a geographically limited basis. The administration initially expressed concerns over these regional recalls. Eventually, however, the administration issued a policy guideline supporting regional recalls under certain conditions. The Center for Auto Safety (the center) (plaintiff) brought suit, arguing that the administration’s policy of allowing regional recalls violated federal safety laws. The center also argued that the administration’s policy guidelines violated the Administrative Procedure Act (the act) because the guidelines were issued without undertaking the requirements of notice-and-comment rulemaking. The administration argued that it had issued only a general statement of policy and thus was not subject to the notice-and-comment requirement. The trial court sided with the administration and dismissed the center’s claims. The Center appealed.