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Motor Vehicle Mfrs. Ass'n v. State Farm Mutual Automobile Ins. Co.

(1983)

Supreme Court of the United States - 463 U.S. 29

tl;dr:

It is arbitrary and capricious for the National Highway Traffic Safety Administration to rescind a rule when the agency did not analyze relevant data or articulate a rational explanation for the agency’s decision.

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ICRAIssue, Conclusion, Rule, Analysis for Motor Vehicle Mfrs. Ass'n v. State Farm Mutual Automobile Ins. Co.

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Facts & HoldingMotor Vehicle Mfrs. Ass'n v. State Farm Mutual Automobile Ins. Co. case brief facts & holding

Facts:The National Highway Traffic Safety Administration (NHTSA) promulgated a regulation...

Holding:Holding (White): A court may set aside an agency’s action...

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Motor Vehicle Mfrs. Ass'n v. State Farm Mutual Automobile Ins. Co. | Case Brief DeepDive
Majority opinion, author: Justice White
Level 1
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The case concerns the NHTSA's decision to revoke the requirement for passive restraints in Motor Vehicle Safety Standard 208, which was estimated to prevent thousands of deaths and injuries annually. The agency failed to provide sufficient explanation for rescinding the requirement, which was found to be arbitrary and capricious by the Court of Appeals. The appropriate scope of judicial review for promulgating and rescinding motor vehicle safety standards is the arbitrary-and-capricious test, which requires the agency to provide a satisfactory explanation for its action and examine relevant data. The agency's determination that detachable automatic belts will not provide anticipated safety benefits does not justify more than an amendment of Standard 208 to disallow compliance by means of the ineffective technology. The agency must provide a cogent explanation for why it exercised its discretion in a particular manner, and the Administrative Procedure Act does not permit such a practice.

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Opinion (Concurring-in-part-and-dissenting-in-part), author: Justice Rehnquist
Level 1
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Justice Rehnquist partially agrees and partially disagrees with the Court's opinion on the agency's decision to rescind the Standard for detachable automatic seatbelts. He believes that the agency provided an adequate explanation for its decision, but agrees that the agency should explain why it rescinded the airbag and continuous spool automatic seatbelt requirements. The Court rejects the agency's explanation for not requiring detachable passive seatbelts, as there are grounds to believe that they would substantially increase seatbelt usage. However, the agency's explanation is adequate as it met the standard of articulating a rational connection between the facts found and the choice made. The agency stated that it will increase its educational efforts to promote public understanding, acceptance, and use of passenger restraint systems.

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