Ralph Nader, Esquire, and Center for Auto Safety, Inc. v. John Volpe, Individually, and as Secretary of the Department of Transportation

466 F.2d 261, 18 A.L.R. Fed. 595, 151 U.S. App. D.C. 90, 1972 U.S. App. LEXIS 11250
CourtCourt of Appeals for the D.C. Circuit
DecidedFebruary 17, 1972
Docket72-1118
StatusPublished
Cited by74 cases

This text of 466 F.2d 261 (Ralph Nader, Esquire, and Center for Auto Safety, Inc. v. John Volpe, Individually, and as Secretary of the Department of Transportation) is published on Counsel Stack Legal Research, covering Court of Appeals for the D.C. Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ralph Nader, Esquire, and Center for Auto Safety, Inc. v. John Volpe, Individually, and as Secretary of the Department of Transportation, 466 F.2d 261, 18 A.L.R. Fed. 595, 151 U.S. App. D.C. 90, 1972 U.S. App. LEXIS 11250 (D.C. Cir. 1972).

Opinion

SPOTTSWOOD W. ROBINSON, III, Circuit Judge.

The National Traffic and Motor Vehicle Safety Act of 1966 1 directs the Secretary of Transportation to establish federal standards for motor vehicles to meet the need for increased safety on the Nation's highways. 2 On March 3, 1971, pursuant to that mandate, the National Highway Traffic Safety Administration, a unit of the Department of Transportation, issued an order 3 promulgating Motor Vehicle Standard No. 208, which would inaugurate passive occupant restraint systems in automobiles manufactured on and after August 15, 1973. 4 Standard No. 208 requires the installation in 1976 and later models 5 of systems meeting specified performance criteria for the protection of all occupants against all types of crashes. 6 The standard, however, extended to manufacturers an option to provide in 1974 and 1975 models 7 systems affording protection only to front-seat occupants against head-on collisions. 8

*263 Automakers filed petitions with the Administration for reconsideration of Standard No. 208, 9 and in the Court of Appeals for the Sixth Circuit for judicial review. 10 On September 29, 1971, the Administration, in response to the petitions for reconsideration, issued its Notices 12 and 13 in the proceeding. Notice 12, among other things, acknowledged the Administration’s recognition of some merit in manufacturers’ protests that there was not enough time to permit the large-scale introduction of passive restraint systems in 1974 model cars, even for just front-seat occupants. 11 Accordingly, Notice 12 stated the Administration’s intention to offer manufacturers a third option as to installations in 1974 and 1975 models. 12 Notice 13, in turn, specified as that option front-seat belts with an ignition interlock in lieu of a passive restraint system, 13 and fixed November 2, 1971, as the date by which any comments on the proposed change were to be submitted to the Administration. 14

Appellants oppose elimination of the minimum requirement of Standard No. 208 that passive restraint systems for front-seat occupants be installed in 1974 and 1975 model automobiles. They complained to the Administration that there were reports, published and unpublished, that just prior to issuance of Notices 12 and 13 personnel in the Office of the President had communicated with the Department and the Administration in support of the manufacturers’ effort to ease the interim 1974-75 edict. Appellants endeavored to have the alleged cornmunieations made a part of the agency’s public docket so that their own comments could be directed in part to what they believed to be political pressure to delay the advent of passivity in occupant protection.

Failing in that effort, appellants filed an action in the District Court on October 18, 1971, approximately three weeks before the deadline for comments on the modification contemplated by the new notices. The action sought a mandatory injunction directing that all written communications between the Office of the President and the Department or the Administration be placed in the public docket, and that memoranda describing all oral communications between them be prepared and likewise placed in the docket. Appellants asserted that unless the docket was so implemented they would not be able to effectively exercise their right to comment on the proposals contained in the notices.

Appellees vigorously resisted appellants’ bid for such disclosure. They argued that intra-governmental communications need not be included in an informal rule-making docket, and that appellants had not demonstrated such a likelihood of success on the merits as would justify a preliminary injunction. They pointed to the fact that the administrative record was already under review — as to Standard No. 208 — in the Sixth Circuit, and urged that appellants’ effort to supplement the record could properly be made only there. Their opposition also included a motion to dismiss appellants’ action on the ground *264 that the statutory scheme for judicial review of automotive safety standards deprived the District Court of subject-matter jurisdiction.

The District Court heard argument on appellants’ motion for a preliminary injunction on October 28, 1971, just a week before the deadline for comments. The court also conducted an in camera examination of a number of documents which it ordered the Administration to produce for that purpose. During the course of the proceedings, the court restrained the issuance of any new regulations based on Notices 12 and 13 until the expiration of ten days from its disposition of the ease unless appellants commented in the meantime. By orders entered on January 28, 1972, the motion for preliminary injunction was denied and the complaint was dismissed. 15

The District Court’s order on the motion for preliminary injunction was accompanied by comprehensive findings of fact and conclusions of law. 16 In the court’s view, some of the documents submitted for in camera inspection were “intra-government communications,” 17 and the others were “working documents, reports and memoranda relating to the studies, deliberations and considerations of an inter-agency ad hoc committee involving costs, technological feasibilities, scientific developments and other matters relating to automotive transportation.” 18 None of these documents, the court ruled, was required to be included in the administrative docket, 19 and their absence therefrom precluded neither commentary by appellants on the proposed change nor their participation in the rulemaking proceeding. 20 The court further ruled that the statutory procedure for review of Administration orders in an appropriate court of appeals 21 afforded appellants an adequate remedy for their grievances; 22 that appellants had failed to show irreparable injury from the inaccessibility of the communications sought ; 23 that appellants had similarly failed to show a substantial probability of ultimately prevailing on the merits because “it appears that this Court lacks jurisdiction over the subject matter of this litigation”;

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Bluebook (online)
466 F.2d 261, 18 A.L.R. Fed. 595, 151 U.S. App. D.C. 90, 1972 U.S. App. LEXIS 11250, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ralph-nader-esquire-and-center-for-auto-safety-inc-v-john-volpe-cadc-1972.