Motor Vehicle Manufacturers Association v State Farm Mutual Automobile Insurance Co and Hard Look Review of Agency Actions

Abstract

This brief Article discusses Motor Vehicle Manufacturers Association v. State Farm Mutual Automobile Insurance Co., where the Court struck down a Department of Transportation order rescinding its controversial air bag standard, which required passive restraints (air bags or automatic seatbelts) in all cars. Rescission of the standard was one of the deregulatory goals of the Reagan Administration. In defending the air bag standard rescission, the DOT suggested that the arbitrary and capricious standard required only the rational basis that the due process clause required of congressional statutes. Instead, the Court ruled that the arbitrary and capricious standard demanded a more rigorous substantive hard look review, which required a judicial review that is more scrutinizing than that of the traditionally more deferential version of the arbitrary and capricious standard of review.