|
''Motor Vehicles Manufacturers Association v. State Farm'', , is a United States Supreme Court decision concerning regulations requiring passive restraints in cars. In it, the Court struck down an order by the National Highway Traffic Safety Administration rescinding regulations requiring either airbags or automatic seat belts in new cars. The Court held that the arbitrary and capricious standard for reviewing agency actions applied to rescinding regulations the same as to enacting regulations. It also held that the rescission of the rule requiring some sort of passive restraint was arbitrary and capricious because it failed to consider the alternative of requiring all cars to have airbags. Finally, it held that the agency dismissed the safety benefits of automatic seat belts too quickly. The case is noteworthy not only for its effects on car safety, but also in clarifying the Supreme Court's approach to reviewing agency actions under the Administrative Procedure Act. == Background == The National Traffic and Motor Vehicle Safety Act of 1966 directs the National Highway Traffic Safety Administration (NHTSA) to issue safety standards, saying they "shall be practicable, shall meet the need for motor vehicle safety, and shall be stated in objective terms.". The resulting regulations went through a tumultuous history, with over 60 rulemaking notices, having been amended, rescinded, reimposed, and then re-rescinded. The original rulemaking simply mandated seat belts. However, this soon proved to be ineffective, as more than half of people never wore their seat belt during that time period.〔463 US at 54, n.19〕 So the NHTSA proposed using passive restraint systems - devices which would protect drivers even if drivers took no action other than that necessary to drive the car. The two main proposed mechanisms were automatic seat belts, and airbags. In 1969, the NHTSA proposed a standard requiring installation of some kind of passive restraint for drivers,〔34 Fed. Reg. 11,148-01〕 and later amended this to include all front seat passengers.〔37 Fed. Reg. 3911〕 The regulations adopted required passive restraints for vehicles built after 1975, and allowed those built between 1973 and 1975 to use a system whereby the car wouldn't start unless the seatbelt was in use. This "ignition interlock" option proved unpopular, and resulted in Congress passing the Motor Vehicle and Schoolbus Safety Amendments of 1974, which disallowed ignition interlocks, and required restraint systems other than seat belts to be approved by Congressional resolution before going into effect.. In 1976 the optional alternatives were extended indefinitely by Secretary of Transportation William Coleman, and the passive restraint requirement suspended, due to expected public resistance. They were then reinstated by Coleman's successor, Brock Adams, and then re-rescinded by his successor, Andrew Lewis. The last rescission is the action which the Supreme Court reviewed.〔463 US at 34-38〕 The NHTSA justified this rescission by saying that there was no longer sufficient evidence for the efficacy of the regulations. This was due not to a change in judgment about the technology, but due to a change in car manufacturers' plans. Whereas the NHTSA originally estimated that 40% of new cars would have automatic seat belts, it turned out that 99% of cars would use them. In addition, they were going to use a detachable type of automatic seat belt, which could easily be detached, at which point they would operate like normal seat belts. The NHTSA also worried that the change would be expensive, and would sour the public's view towards safety regulations, as it would be seen as a wasteful, imposing example of bureaucratic overreach.〔463 US at 38-39〕 Though the DC Circuit found that rescinding a rule has "parallels" to failing to act, and agency's failure to act was only subject to "very narrow" review,〔680 F.2d 206, 219〕 thus suggesting a narrow review in the case of rescission, they still vacated the rescission, partially due to Congressional action in response to NHTSA regulations, which they saw as heightening the standard of review. They gave three reasons for vacating the rescission: that there was insufficient evidence to sustain the conclusion that they could not predict an increase in seat belt usage, and that "only a well-justified refusal to seek more evidence could rencer rescission non-arbitrary";〔680 F.2d 206, 232〕 that the NHTSA inadequately considered the possibility of requiring nondetachable automatic seat belts; and that they inadequately considered the possibility of requiring airbags. 抄文引用元・出典: フリー百科事典『 ウィキペディア（Wikipedia）』 ■ウィキペディアで「Motor Vehicles Manufacturers Ass'n v. State Farm Mutual Automobile Insurance Co.」の詳細全文を読む スポンサード リンク
|