Center for Auto Safety v. National Highway Traffic Safety Administration

As automakers began issuing voluntary vehicle recalls limited to specific geographic regions, the National Highway Traffic Safety Administration (defendant), initially skeptical, eventually issued a policy guideline supporting regional recalls under certain conditions; the Center for Auto Safety (plaintiff) sued, arguing the guideline violated federal safety law and, separately, that it should have gone through APA notice-and-comment rulemaking rather than being issued as a mere guideline. The trial court sided with the administration, finding the guideline exempt from notice-and-comment requirements as a general policy statement, and the Center appealed.