Motor Vehicle Manufacturers Association v. State Farm Mutual Automobile Ins. Co.

463 U.S. 29, 103 (1983)


The department of transportation began instituting a mandatory passive restraint regulation which phased in the requirement that large vehicles have seat belts or air bags. However, a new Secretary of Trans assumed office and ordered a one year delay. The agency issued notice and received written comments and held a public hearing and finally issued a rule that retracted the passive restraint requirement. In issuing the rule, the agency justified the retraction of the rule by stating that it could no longer find enough safety benefits resulting from the use or airbags and safety belts to justify the rule. The ruling wasn’t the result of safety belts and airbags’ ineffectiveness in preventing death. It was retracted because it was clear to the agency that 99% of manufacturers were installing automatic seat belts in their cars anyway. Therefore, the benefits of airbags were no longer apparent. MVMA believes the court should evaluate the rule retraction on the basis of a narrower test than the arbitrary and capricious test.


Whether there is a rational relationship between the facts cited by the agency and the retraction of the rule (whether the rule was arbitrary and capricious).


“The agency’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.” The court is to review the decision to see if there should is a “rational connection between the facts found and the choice made.”


No, there was not a rational relationship and the decision was arbitrary and capricious. Rescission of a restraint requirement is not arbitrary and capricious where there is no evidence to support that retracting the regulation will result in increased safety. BUT, “substantial uncertainty” is not a justification for retracting the rule. “The agency must explain the evidence which is available and must offer a rational connection between the facts found and the choice made.”

The court reviewed the facts and found no “direct evidence” supporting their decision. Survey results indicated that drivers were much more likely to wear their seatbelt. However, the agency claims that these studies are unreliable, which is in their legitimate discretion. The court says, however, that a passive belt requires affirmative action and undertakes a common sense analysis, essentially stating that the agency didn’t even consider the basic fact that a seatbelt which automatically is put on the occupant will increase seatbelt use. “While the agency is entitled to change its view on the acceptability of continuous passive belts, it is obligated to explain its reasons for doing so.”


The agency’s explanation was no arbitrary and capricious. The change in policy is most likely due to a change in administration, which is legitimate. “As long as the agency remains within the bound established by Congress, it is entitled to asses administrative records and evaluate priorities in light of the philosophy of the administration.”

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