Motor Vehicle Mfrs. Ass'n v. State Farm Mut. Auto. Ins. Co.

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In Motor Vehicle Mfrs. Ass'n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983), the U.S. Supreme Court held that a federal agency under the Reagan Administration had acted in an "arbitrary and capricious" manner in violation of the Administrative Procedure Act in rescinding a requirement that automobiles have passive restraints (safety belts).

The Court held that it will not vacate an agency's decision unless it:

"has relied on factors which Congress had not intended it to consider, entirely failed to consider an important aspect of the problem, offered an explanation for its decision that runs counter to the evidence before the agency, or is so implausible that it could not be ascribed to a difference in view or the product of agency expertise."

Conservatives quote another phrase in this opinion to justify deferring to agency decisions:

"We will, however, 'uphold a decision of less than ideal clarity if the agency's path may reasonably be discerned.'" Ibid. (quoting Bowman Transp., Inc. v. Arkansas-Best Freight System, Inc., 419 U.S. 281, 286 (1974)).