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Motor Vehicle Manufacturers’ Association v. State Farm Mutual Automobile Insurance Co.

United States Supreme Court
463 U.S. 29 (1983)


The National Highway Traffic Safety Administration (NHTSA) issued Modified Standard 208, which mandated the phasing in one of two types of passive restraints in automobiles: airbags and passive seatbelts. Prior to the deadline for complying with the standard, and after the election of a new President of a different political party, the Secretary of Transportation reopened the rulemaking. Two months after reopening the rulemaking, the NHTSA ordered a one-year delay in the first application of the standard and proposed the possible rescission of the entire standard. After receiving written comments and holding public hearings, the NHTSA issued a final rule rescinding Modified Standard 208’s passive restraint requirement. In rescinding this requirement, the NHTSA stated that it could no longer find—as it had prior to the initial proposal of the rule—that such a requirement would produce significant safety benefits. This judgment did not reflect a change of opinion regarding the effectiveness of the technology, but a change in plans by the automobile industry. Specifically, at the time of the rescission, it was apparent that manufacturers planned to install automatic seatbelts in approximately 99% of new cars.

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