Decided in 1983, one year before Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., the Court found that the National Highway Traffic Safety Administration had not provided a "reasoned analysis" for rescinding regulations that required either airbags or automatic seat belts in new cars.

The case is noteworthy not only for its effects on car safety but also in clarifying the Court's approach to reviewing agency actions under the Administrative Procedure Act.

In 1969, the NHTSA proposed a standard requiring installation of some kind of passive restraint for drivers,[4] which was later amended to include all front seat passengers.

[6] In 1976, the optional alternatives were extended indefinitely by Secretary of Transportation William T. Coleman Jr., and the passive restraint requirement suspended because of expected public resistance.

It gave the following reasons for vacating the rescission: there was insufficient evidence to sustain the conclusion that it could not predict an increase in seat belt usage and "only a well-justified refusal to seek more evidence could render rescission non-arbitrary,"[10] the NHTSA had inadequately considered the possibility of requiring nondetachable automatic seat belts, and it had inadequately considered the possibility of requiring airbags.

Justice White, writing for the majority, disagreed with the DC Circuit and held that the scope of judicial review is the same for rescission as it is for enacting regulations in the first place.

"[11] It also rejected the view that the congressional action, after the enactment of the National Traffic and Motor Vehicle Safety Act, had affected the standard of review even if it could inform the Court's interpretation of the statute.

A change in administration brought about by the people casting their votes is a perfectly reasonable basis for an executive agency's reappraisal of the costs and benefits of its programs and regulations.

Nevertheless, the agency must examine the relevant data and articulate a satisfactory explanation for its action including a rational connection between the facts found and the choice made.