Motor Vehicle Manufacturers Association of the United States, Inc. v. State Farm Mutual Automobile Insurance Company (1982)
- Docket
- 82-354
- Decided
- 1982-01-01
Summary
Question: Was the NHTSA’s decision to rescind Modified Standard 208 arbitrary and capricious? Conclusion: Yes. Justice Byron R. White delivered the opinion of the unanimous Court. The Supreme Court held that the rescission of a standard should be reviewed based on whether the decision was arbitrary or capricious. Because the removal of a standard often entails the same level of policy changes as the promulgation of a law, it should be reviewed under the same tests. The Court also held that the Court of Appeals, while correctly finding that the rescission was arbitrary and capricious, relied too strongly on an inferred congressional mandate for passive restraints. The Court held that, by rescinding Modified Standard 208 without considering alternatives and consequences, the NHTSA did not provide evidence for its decision and therefore acted arbitrarily and capriciously. In his opinion concurring in part and dissenting in part, Justice William H. Rehnquist wrote that the NHTSA did not provide adequate analysis for rescinding the requirements regarding airbags and continuous spool seat belts, but it did explain its decision in regards to detachable belts. He also argued that it is reasonable for an agency to reassess its priorities over time, as happened in this case. Chief Justice Warren E. Burger, Justice Lewis F. Powell, Jr., and Justice Sandra Day O’Connor joined in the partial concurrence and partial dissent.