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Southland Mower Co. v. Consumer Product Safety Commission

United States Court of Appeals for the Fifth Circuit
619 F.2d 499 (1980)


Facts

The Consumer Product Safety Commission (Commission) (defendant) promulgated safety regulations for lawnmowers. The Commission relied on the fact that that 77,000 people were injured by lawnmowers each year, and an economic-impact report, to find that lawnmower-safety regulations were reasonably necessary and in the public interest. The report estimated the increased price of a lawnmower compared to the saved medical costs that would result from regulations. The regulations contained three requirements. (1) A lawnmower was required to pass a foot-probe test to ensure that the blades would not injure the user’s feet. The regulation required the lawnmower to pass the test both at the rear of the lawnmower where the user walked and at the discharge chute on the side of the lawnmower. Southland Mower Company and other lawnmower manufacturers (plaintiffs) argued that the discharge chute’s foot-probe test was not reasonably necessary to reduce injury. The Commission presented evidence of only one injury caused by blades at the discharge chute. (2) A lawnmower was required to have a blade-control system that stopped the blades within three seconds of the user’s hands leaving the handle. The Commission conducted field tests on the times people took to move their hands from the handle to the blade. The plaintiffs argued that the three-second timeframe was too quick, and that allowing more time would decrease costs. (3) A lawnmower was required to have an appropriate warning label. The plaintiffs petitioned for review, claiming that the regulations were not reasonably necessary or in the public interest.

Rule of Law

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Issue

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Holding and Reasoning (Gee, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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