Not a Lexis Advance subscriber? Try it out for free.

Motor Vehicle Mfrs. Ass'n v. State Farm Mut. Auto. Ins. Co.

Supreme Court of the United States

April 26, 1983, Argued ; June 24, 1983, Decided

No. 82-354

Case Summary

Procedural Posture

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.

Overview

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 Subsequently, the NHTSA promulgated rules to require passive restraint systems in new vehicles, but then rescinded the requirement on the basis that it was no longer able to find that the requirement would produce significant safety benefits.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 appellate court held that the NHTSA's rescission was arbitrary and capricious. Petitioners sought a writ of certiorari, which was granted. 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.

Outcome

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.

LexisNexis® Headnotes

 

 

Administrative Law > Agency Rulemaking > Informal Rulemaking

Business & Corporate Compliance > ... > Transportation Law > Commercial Vehicles > Maintenance & Safety

Transportation Law > Private Vehicles > Safety Standards > General Overview

Administrative Law > Agency Rulemaking > General Overview

Administrative Law > Judicial Review > Standards of Review > General Overview

Administrative Law > Judicial Review > Standards of Review > Abuse of Discretion

Administrative Law > Judicial Review > Standards of Review > Arbitrary & Capricious Standard of Review

HN1  Agency Rulemaking, Informal Rulemaking

Both the National Traffic and Motor Vehicle Safety Act of 1966, 15 U.S.C.S. § 1381 et seq., and the 1974 amendments concerning occupant crash protection standards indicate that motor vehicle safety standards are to be promulgated under the informal rulemaking procedures of the Administrative Procedure Act. 5 U.S.C.S. § 553. The National Highway Traffic Safety Administration's action in promulgating such standards therefore may be set aside if found to be arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law. 5 U.S.C.S. § 706(2)(A).

 

Administrative Law > Judicial Review > General Overview

Business & Corporate Compliance > ... > Transportation Law > Commercial Vehicles > Maintenance & Safety

Transportation Law > Private Vehicles > Safety Standards > General Overview

Administrative Law > Judicial Review > Standards of Review > General Overview

Environmental Law > Administrative Proceedings & Litigation > Judicial Review

HN2  Administrative Law, Judicial Review

Section 103(b) (15 U.S.C.S. § 1392(b)) of the National Traffic and Motor Vehicle Safety Act of 1966, 15 U.S.C.S. § 1381 et seq., states that the procedural and judicial review provisions of the Administrative Procedure Act shall apply to all orders establishing, amending, or revoking a federal motor vehicle safety standard, and suggests no difference in the scope of judicial review depending upon the nature of the National Highway Traffic Safety Administration's action.

 

Administrative Law > Agency Rulemaking > Formal Rulemaking

Business & Corporate Law > Agency Relationships > Termination > General Overview

HN3  Agency Rulemaking, Formal Rulemaking

A settled course of behavior embodies an agency's informed judgment that, by pursuing that course, it will carry out the policies committed to it by Congress. There is, then, at least a presumption that those policies will be carried out best if the settled rule is adhered to. Accordingly, an agency changing its course by rescinding a rule is obligated to supply a reasoned analysis for the change beyond that which may be required when an agency does not act in the first instance.

Access the full text caseNot a Lexis Advance subscriber? Try it out for free.

463 U.S. 29 ; 103 S. Ct. 2856 ; 77 L. Ed. 2d 443 ; 1983 U.S. LEXIS 84 ; 51 U.S.L.W. 4953; 13 ELR 20672

MOTOR VEHICLE MANUFACTURERS ASSOCIATION OF THE UNITED STATES, INC., ET AL. v. STATE FARM MUTUAL AUTOMOBILE INSURANCE CO. ET AL.

Prior History:  [1]  CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT.

Disposition:  220 U. S. App. D. C. 170, 680 F.2d 206, vacated and remanded.