# Respondents Brief — Motor Vehicle Mfrs. Assn. of United States, Inc. v. State Farm Mut. Automobile Ins. Co.

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## Record

- **Collection:** Supreme Court brief
- **Document type:** Respondents Brief
- **Published:** January 1, 1983
- **Citation:** 463 U.S. 29

## Text

Nos. 82-354, 82-355, 82.398 Office-Supreme Court, US.
D

IN THE FEB 9 1983
States

Supreme Cont of the Brite ALEXANDER L STF vas,

October Term, 19f ‘* rASRA |

Motor VEHICLE MANUFACTURERS ASSOCIATION OF THE
Unitep States, Inc., et al.,

Petitioners,

against
State Farm MutTvat AvuTomosite INsuRANCE Company, ef ail.,
Respondents.

ConsuMER ALERT AND Pacific Lecat FouNDATION,

Petitioners,

against
Strate Farm Mutvat AvuTomosite InsurANCE Company, ef ai.,
Respondents.

Unitep States DEPARTMENT OF TRANSPORTATION, e¢ al.,

Petitioners,

against
Strate Farm Mutrvat Avtomospite INsurANce Company, ef al.,
Respondents.

On Petitions for Writs of Certiorari to the United States
Court of Appeals for the District of Columbia Circuit

BRIEF FOR RESPONDENT SUPERINTENDENT
OF INSURANCE OF THE STATE OF NEW YORK

Rosert ABRAMS

Peter H. Scuirr Attorney General of the
Acting Attorney-in-Chief State of New York
Appeals and Opinions Attorney for Respondent

Rowers § Hance Syecrears ewe

Ra wo Wor ter
Assistant Attorney General New York, New York 10047

MartTINn Massowrzs (212) 488-2464
Deputy Superintendent and
General Counsel

Mitton L. oe
and Counsel
New York State Insurance Department

Of Counsel

Question Presented

Whether the revocation by the National Highway
Traffic Safety Administration (NHTSA) of the ‘‘passive
restraint’’ requirements of Federal Motor Vehicle Safety
Standard 208 was arbitrary, capricious and unlawful?

Itt

TABLE OF CONTENTS

PAGE
Question Presented 1
Opinions Below 2
Jurisdiction 2
Statutes Involved 2
Statement of the Case 3
Summary of Argument 3
Point I—The Judgment of the Court of Appeals Was
in Full Accord with the Administrative Procedure
Act 3
Point Il—Retention of the Passive Restraint Stand-
ard Will Clearly Protect Automobile Passengers
from Death and Serious Injury and Result in
Substantial Keonomic Savings 5
Point III—NHTSA’s Rescission of the Passive Re-
straint Portion of Standard 208 Was Arbitrary,
Capricious and Unlawful 11

Conclusion a z 15

IV
TABLE OF AUTHORITIES

Cases:

Citizens to Preserve Overton Park v. Volpe, 401 U.S.
402 (1971) . !

Industrial Union Dep’t v. American Petroleum Insti-
tute, 448 U.S. 607 (1980)

Montgomery v. Daniels, 38 N.Y.2d 41, 340 N.E.2d 444,
378 N.Y.S. 2d 1 (1975)

Ostrer v. Schenck, 41 N.Y.2d 782, 364 N.E.2d 1107, 396
N.Y.S. 2d 335 (1975) .

State Farm Mutual Automobile Insurance Company v.
United States Department of Transportation, 680
F.2d 206 (D.C. Cir. 1982)

Statutes:

Administrative Procedure Act, Section 10(e) (5 U.S.C.
> ae

National Traffic and Motor Vehicle Safety Act of 1966,
Section 103 (15 U.S.C. § 1392)

5 U.S.C. § 706(2)(A)
15 U.S.C. § 1381 - |
15 U.S.C. § 1391(1)(2)
15 U.S.C. § 1392(a)

15 U.S.C. § 1394(a)(1) ...
15 U.S.C. § 1394(a) (4)

15 U.S.C. § 1397(a)(2)(A) .
28 U.S.C. § 1254(1)
42 U.S.C. 6402
42 U.S.C. § 423 ....

PAGE

cons

42 U.S.C. § 601

42 U.S.C. § 1381

N.Y. Insurance Law § 10

N.Y. Insurance Law, Art. VITA (§§ 175-179)
N.Y. Insurance Law, Art. VIII (§§ 180-189)
N.Y. Insurance Law § 670, et seq.

N.Y. Insurance Law § 671(4)

N.Y. Insurance Law § 678

N.Y. Social Services Law § 157

Federal Motor Vehicle Safety Standard 208

Other Authorities:

4,10
passim

Hartunian, et al., ‘‘ The Incidence and Economic Costs
of Cancer, Motor Vehicle Injuries, Coronary
Heart Disease, and Stroke: A Comparative

Analysis’’, 70 Am. J. Public Health 1249 (1980)

N.Y. Times, Jan. 29, 1983, p. 12, col. 1
N.Y. Times, Feb. 3, 1983, p. D2, col. 1

Status Report, Vol. 16, No. 9, p. 1 (Insurance Institute

For Highway Safety, June 24, 1981)

Status Repori, Vol. 18, No. 1, p. 2 (Insurance Institute

For Highway Safety, January 18, 1983)

Nos. 82-354, 82-355, 82-398

IN THI!

Supreme Court of the United States

October Term, 1982

Motor Venice MANUFACTURERS .\SSOCIATION OF THE
Unitep States, Inc., ef al...
Petitioners.
against

Strate Farm Mutuart \cTromospite INsurANcE Company, ef al.,

Respondents.

CoNSUMER ALERT AND Paciric L&eGAL FouNpDATION,
Petitioners,
agaist

State Farm Mutvar .\vromort.e INsurANcE ComMPpaANy, et al.,

Respondents.

Unirep STATES DEPARTMENT OF TRANSPORTATION, ef al.,
Petitioners.
against

State Farm Mutuat A\vromorire Insurance Company, et al..
Respondents.

On Petitions for Writs of Certiorari to the United States
Court of Appeals for the District of Columbia Circuit

BRIEF FOR RESPONDENT SUPERINTENDENT
OF INSURANCE OF THE STATE OF NEW YORK

Opinions Below
The June 1, 1982 opinion of the Court of Appeals for
the District of Columbia Cireuit (Pet. App. la-76a)* is
reported at 680 F.2d 206. The August 4, 1982 supplemental

order and memorandum of the Court of Appeals (Pet. App.
79a-82a) are not reported.

Jurisdiction

The jurisdiction of the Court of Appeals was invoked
pursuant to 15 U.S.C. § 1394(a)(1). The judgment of the
Court of Appeals (Pet. App. 160a-161a) was entered on
June 1, 1982, and the supplemental order of the Court of
Appeals (Pet. App. 79a-80a) was entered on August 4, 1982.
The petitions for a writ of certiorari in Nos. 82-354 and
82-355 were filed on August 30, 1982. On August 24, 1982,
the Chief Justice extended the time for filing a petition for
a writ of certiorari in No. 82-398 to and including Septem-
ber 8, 1982, and the petition was filed on that date. The
petitions for a writ of certiorari were granted on November
8, 1982. The jurisdictions of this Court rests upon 28
U.S.C. § 1254(1) and 15 U.S.C. § 1394(a) (4).

Statutes Involved

Section 103 of the National Traffic and Motor Vehicle
Safety Act of 1966, 15 U.S.C. § 1392, and Section 10(e) of
the Administrative Procedure Act, 5 U.S.C. § 706, are re-
produced in pertinent part in the Appendix to the Govern-
ment’s brief at la-2a.

* Numbers in parentheses preceded by “Pet. App.” refers to the
quads te logins ter 0 Gn denen fled te No. 82.384

Statement of the Case

In the interests of brevity, the Court is respectfully
referred to the statement of the case contained in the briefs
submitted by the other respondents and in the opinion of
the Court of Appeals (Pet. App. 4a-24a).

Summary of Argument

The record of these proceedings demonstrates that
NHTSA’s rescission of Federal Motor Vehicle Safety
Standard (FMVSS) 208 was arbitrary, capricious and un-
lawful. The Court of Appeals (Pet. App. 46a et seq.) gave
due deference to the agency’s views and properly employed
the ‘‘rational basis’’ test relied wpon by all parties.

The elimination of passive restraints violated the re-
quirement of the 1966 National Traffic and Motor Vehicle
Safety Act that NHTSA adopt practicable standards to pro-
mote motor vehicle safety. Passive restraints work. They
can be installed in new automobiles at moderate cost,
and will result in direct savings to the consumer in the form
of reduced automobile insurance premiums. Premium dis-
counts for vehicles equipped with passive restraints have
already been adopted by insurers writing two-thirds of the
automobile casualty business in New York. They will be
mandated for the rest of the industry when passive re-
straints are implemented. The reduction in the number of
deaths and the frequency and severity of personal injuries
resulting from front-end collisions will, in addition, neces-
sarily lessen the burden upon private life, accident and dis-

4

ability insurance, workers’ compensation systems, Federal
survivors (42 U.S.C. § 402) and disability insurance (id.
§ 423) ; Supplemental Security Income (id. § 1381), Aid to
Families With Dependent Children (id. § 601) and other
State public assistance programs such as New York’s Home
Relief, N.Y. Social Services Law § 157. Public and private
employers would benefit from less employee time lost due to
accidents and the need to hire substitutes. (ne cannot as-
sign a dollar amount to the fewer widows and orphans,
crippled and maimed that would result from the mandated
use of passive restraints.

Regrettably, the Government has approached the re-
quirement for passive restraints in an entirely irresponsible
fashion. NHTSA first allowed the automobile industry to
‘**comply’* with Standard 208 by approving what it subse-
quently concluded was an easily defeasible seatbelt that
was not a passive restraint at all. NHTSA could have
moved to modify its standard if it determined it was de-
fective. Rather, it invoked its own failure to enforee Stand-
ard 208 as an excuse to dispense with it entirely. When
called to account by the Court of Appeals, its response was
to propose yet additional, open-ended ‘‘study’’ of a mat-
ter which had been ‘‘studied’’ for well over a decade.
NHTSA’s approach to automobile passenger safety is to
engage in a demonstrably ineffective program of ‘‘educat-
ing’’ the public to voluntarily use the presently mandated
seatbelt system. Meanwhile, the needless slaughter on the
highways goes on.

ARGUMENT
POINT I

The Judgment of the Court of Appeals Was in
Full Accord with the Administrative Procedure Act.

In determining that NHTSA’s rescission of FMVSS 208
was ‘‘arbitrary, capricious, an abuse of discretion or other-
wise not in accordance with law,’’ 5 U.S.C. 4706(2)(A), the
Court of Appeals followed the standard analysis applicable
to informal rule making under the Administrative Proce-
dure Act (Pet. App. 24a, et seq.) which the respondents,
themselves, concede to be the appropriate standard of re-
view. See, ¢.g., Gov't Br. p. 23, et seq.; Consumer Alert Br.
p. 6; see also Citizens to Preserve Overton Park v. Volpe,
401 U.S. 402, 416 (1971) ; Industrial Union Dep’t v. Ameri-
can Petroleum Institute, 448 U.S. 607, 662-63 (1980) (Bur-
ger, C.J., concurring). Little, if anything, need be added to
its opinion in this regard.

POINT II

Retention of the Passive Restraint Standard Will
Clearly Protect Automobile Passengers from Death
and Serious Injury and Result in Substantial Economic

Savings.

In enacting the National Traffic and Motor Vehicle
Safety Act of 1966, it was the express purpose of Congress
to ‘‘reduce traffic accidents and deaths and injuries to per-
sons resulting from traffic accidents,’’ 15 U.S.C. 4 1381. To
that end, Congress mandated that NHTSA adopt safety

standards that are ‘‘practicable [and] meet the need for
motor vehicle safety’’. This is defined as—

‘*the performance of motor vehicles or motor vehicle
equipment in such a manner that the public is protected
against unreasonable risk of accidents occurring as a
result of the design, construction or performance of
motor vehicles and is also protected against unreason-
able risk of death or injury to persons in the event ac-
cidents do oceur, and includes nonoperational safety
of such vehicles.

‘* *Motor vehicle safety standards’ means a minimum
standard for motor vehicle performance, or motor
vehicle equipment performance, which is practicable,
which meets the need for motor vehicle safety and
which provides objective criteria.”” 15 U.S.C. § 1391
(1)(2).
See also: 15 U.S.C. § 1392(a). By deleting from Standard
208 the requirement of automatic or passive restraints for
the front seats of passenger cars—a measure that would
offer substantial protection from bodily injury and the re-
sulting economic loss—NHTSA failed to meet these statu-
tory requirements. The clear effect of passive restraints in
fulfilling the cost-effectiveness and practicability require-
ments of the statute can be seen in the area of automobile
insurance. The pervasive role of the automobile as a major
means of transportation has made automobile insurance
coverage an essential form of protection. As regulator of
the insurance industry in the State of New York,* the Su-
perintendent of Insurance is the guardian of the State’s

* The Superintendent of Insurance of the State of New York is
charged with the rights, powers and duties express or implied by the
Insurance Law in connection with the supervision of the business of
insurance in New York, N.Y. Insurance Law § i0, Ostrer v. Schenck,
41 N.Y.2d 782, 785, 364 N.E.2d 1107, 1108, 1109, 396 N.Y.S.2d 335,
336-337 (1975). Other state insurance regulators have similar powers.

7

compelling interest in assuring the availability, at reason-
able cost, of insurance protection against economic losses
due to automobile accidents.

States such as New York have, in recent years, sought
to reduce the cost of automobile insurance by such means
as eliminating unnecessary litigation, through ‘‘no-fault’’
laws ; making the payment of claims more efficient, and con-
trolling the cost of medical care, N.Y. Insurance Law § 670,
et seq.; § 678; Montgomery v. Daniels, 38 N.Y.2d 41, 49-52,
340 N.E.2d 444, 448-450, 378 N.Y.S. 2d 1, 7-10 (1975). The
cost of insurance must, however, reflect anticipated claims.
No matter how efficient the system is, only a reduction in the
frequency and severity of automobile injuries holds a prom-
ise of large-scale premium reductions. (See generally,
_ affidavit of Superintendent of Insurance Albert B. Lewis,
sworn to December 22, 1981 in support of motion to inter-
vene in Court of Appeals.)

These objectives, as well as those of Congress in legis-
lating the Safety Act, are advanced by the requirement for
passive restraints. During the course of the administrative
proceedings, Dr. William Nordhaus, Professor of Econom-
ies, Yale University and a former member of the Presi-
dent’s Council of Economic Advisors, testified without con-
tradiction that the failure to employ passive restraints
vould result in an annual increase of 6,400 fatalities and at
least 120,000 moderate to critical injuries, resulting from
front-end collisions (Pet. App. 122a). These facts are not
new ; they have been conclusively established over the more
than two decades in which automobile passenger safety
research has been conducted and are conceded by NHTSA
in its own analyses (Pet. App. 14a-15a, 94a). On the other

8

hand, the mandatory introduction of passive restraints
would necessarily be translated into fewer and less expen-
sive bodily injury claims and the savings would be passed
on to the consumer.

As the Court of Appeals observed (Pet. App. 65a, n. 37),
it is the Superintendent’s intent to require all automobile
insurers to introduce discounts on the personal injury por-
tion of automobile insurance premiums applicable to cars
equipped with proper passive restraint systems. They
would be based upon reasonable projections of the expected
reductions in the frequency and severity of injuries to pas-
sengers in motor vehicles so equipped. Anticipated per-
formance would be reflected in lower automobile insurance
premiums charged for such vehicles. Thus, whatever the
consumer spends on airbags or other passive restraints may
well be offset by premium savings alone.

It has been estimated that airbags, the most effective
passive restraint, could be installed at a cost to the con-
sumer of $200-$300, assuming the economics of mass pro-
duction (Pet. App. 16a)." Since the average bodily injury
portion of a New York no-fault premium is $75.00 per year,
the 25-30% anticipated discount would translate into a total
saving of $300 over a ten-year life of the average vehicle.

Bodily injury liability insurance premiums are closely
related to the severity and cost of ‘‘no-fault’’ claims, since,

* The $800-$900 estimate for the 4,000 cars in which Mercedes-
Benz plans to install airbags, N.Y. Times, Jan. 29, 1983, p. 12, col. 1,
is clearly excessive for mass production and universal installation. A
stark contrast to the mere ten per cent installation in a luxury car
that i Ne ee ee ee a
<4 as an optional extra. N.Y. Times, Feb. 3, 1983, p. D2,

9

by definition, New York limits tort actions to ‘‘serious
injuries’’, as defined in N.Y. Insurance Law §671(4).
Bodily injury settlements and judgments tend to be multi-
ples of special damages, i.¢., medical costs and lost wages
which are payable under no-fault.

Since the severity and frequency of serious injuries will
be reduced by passive restraints, a reduction of the bodily
injury premium will necessarily follow. At present, the
average bodily injury liability rate is $150, per year. As-
suming an anticipated saving of only fifteen percent, per
year over the same ten-year period—a most conservative
estimate—the savinge on this coverage would be another
#300. Thus, the automobile insurance premium savings
would more than offset the cost of universally installed

airbags.”

It is also most significant that companies insuring more
than two-thirds of the automobile risks in the State of New
York have already filed rating plans which offer from
twenty-five to thirty percent discounts on the Personal in-
jury Protection (no-fault) portion of automobile insurance
premiums. This is a clear recognition by the insurance
industry’s actuaries ef the expected reduction in the fre-
quency and severity of death and injury to passengers in
automobiles equipped with passive restraints. Upon the
implementation of Standard 208, all insurers will be re-
quired to file rates which provide for appropriate passive
restraint discounts. Such action would be based upon the
Superintendent’s statutory authority, N.Y. Insurance Law

the New York State
which are
4 public

* The foregoing analysis was 1
I the
eats Eas ei basis of rate
rates of 8% annually.

10

Art. VII-A (Seetions 175-179-a inclusive—‘‘Rate Regula-
tion and Promotion of Competition’’) and Article VII
(Sections 180-189 inelusive—‘‘ Rates and Rating Organiza-
tiens’’) of the New York Insurance Law which provide
that rates shall not be ‘‘exeessive, inadequate or unfairly
discriminatory’? (N.Y. Ins. Law §§175 and 180). Other
states exaploy comparable standards in their evaluation
of filed rates.

In addition to the direct savings to the consumer in the
form of lowered insurance premiums, the economy, as a
whole, will derive significant benefits from the manlatory
iastaliation of passive restraints. One must bear in mind
that the cost of automobile related death and injury is borne
not only by private life, accident and disability insurers,
but by workers’ compensation systems, Federal Social Secu-
rity survivors (42 U.S.C. § 402) and disability (id. § 423)
insurance, as well." The frequent need to replace a tem-
porarily disabled worker places additional burdens on
private and public employers alike. When private insur-
ance, workers’ compensation and payroll-tax funded Social
Security programs are insufficient to support the injured
parties, the burden falls directly upon the taxpayer in the
form of claims for Supplemental Security Income (42
U.S.C. § 1381), Aid To Families With Dependent Children
(id. § 601) and other state public assistance programs such
as New York’s Home Relief, N.Y. Social Services Law
§ 157.

ll

In the final analysis, however, one can never put a price
tag on the broken bodies, broken families and shattered
dreams that result from the needless death and injury that
could be so easily avoided by the mandatory installation of
passive restraints.

POINT III

NHTSA’s Rescission of the Passive Restraint Por-
8 ae St ee Sa Capea ae

A.

Althongh the National Traffic and Motor Vehicle Safety
Act views with disfavor any practice which renders a
safety device inoperative, 15 U.S.C. §1397(a)(2)(A),
NHTSA determined that a detachable seatbelt meets the
requirement of Standard 208 and that, accordingly, auto-
mobile manufacturers may choose such a system instead of
a non-detachable seatbelt or airbags." But NHTSA rea-
soned, since the public can, and most people will, disengage
detachable safety devices, Standard 208 would not achieve
its purpose insofar as it related to passive restaints (Pet.
App. 96a-105a). NHTSA’s reasoning is contrary to clear
Congressional mandate that effective mechanisms be in-
cluded in motor vehicles to reduce the severity of injuries.**
If NHTSA was unconvinced as to the performance of de-

* Compare the V. and Chevette, which feature automatic
seatbelts with ignition i (Pet. App. cyte

** On the contrary, adoption of NHTSA's at a time when
smaller, lighter motor vehicles are replacing , More protective
vehicles, could result in an increase in the severity of injuries and loss
of life (Pet. App. 14a).

12

tachable belts, iis duty was to require industry to offer a
system which truly functioned as a passive restraint. As
the Court of Appeals noted (Pet. App. 72a), the evidence,
indeed, justified requiring the installation of airbags as the
sole form of passive restraint.”

Much has been said by NHTSA and the automobile man-
ufacturers as well as some of their supporters that govern-
ment ought not to require manufacturers to install passive
restraints in automobiles, but should, instead, educate the
public to the value of voluntarily utilizing the lap-shoulder
belts presently in use. Sec, e.g., Pet. App. 110a-112a, 126a).
They advocate an educational campaign to use present seat-
belt systems as a substitute for passive restraints with the
full knowledge that such efforts have been an abysmal fail-
ure wherever tried, Siafus Report, Vol. 16, No. 9, p. 1 (In-
surance Institute For Highway Safety, June 24, 1981). In-
deed, Congressional skepticism as to the effieacy of spend-
ing money for educational campaigns which have proven to
have no lasting effect was highlighted by its refusal to allow
funds for such use, unless the Government required its own
employees to use seatbelts and set specifie goals against
which the Congress could measure their worth, Status Re-
port, Vol. 18, No. 1, p. 2 (Insurance Institute For Highway
Safety, January 18, 1983).

* Except for forbidding the automatic ignition interlock, Con-
gress has given free rein to NHTSA to wage Fo —
a

specific methods to achieve results, its refusal to mn sy with the
passive restraint concept reflects an ongoing awareness and tacit

13

The demonstrated futility of attempting to educate the
public to voluntarily use lap and shoulder belts is but one
more argument in favor of mandatory passive restraints.°

Thus, as Circuit Judge Mikva found (Pet. App. 74a), the
administrative record demonstrates that NHTSA’s rescis-
sion of Standard 208 was completely unjustified. As the
Court of Appeals later noted, the agency showed no inten-
tion of setting its house in order by addressing the points
diseussed in that Court’s opinion (Pei. App. 82a, 85a), but
instead attempted to thwart its mandate by proposing yet
an additional period of open-ended ‘‘study’’ (Pet. App.
130a, 139a, ef seq.).

Cc.

It is, we suggest, significant that the National Associ-
ation of Insurance Commissioners (NAIC), representing
the insurance regulators of every state, commonwealth and
territory, has, by unanimous resolution, determined to par-
ticipate in this appeal as amicus curiae to urge affirmance
of the judgment below. The NAIC acted with rare unanim-
ity, demonstrating that not only the insurance industry as
a whole but the insurance regulators view NHTSA’s action
here to be irresponsible and contrary to the public interest.
Neither we nor the other regulators believe that the Court
of Appeals’ action involved any usurpation of the power of

equipment
App. 6a, n). Now beter is repeating itself with oa cae,
for voluntary self-protection.

14

the Executive. indeed, it is the Executive Branch that has
abdicated its responsibility to implement the will of Con-
gress. It was nothing less than the Court of Appeals’ ob-
ligation to require NHTSA to adhere to the statutory
mandate.

The Government’s request for a remand for further
proceedings should be denied and the Court of Appeals’
order that passive restraints remain part of Standard 208
affirmed. No useful purpose can be served by remanding to
the agency for further administrative proceedings. It
would only result in the continuation of the present attempt
by NHTSA to undo over two decades of research and devel-
opment and regulatory history and to repeal by administra-
tive fiat the Congressional mandate to establish practicable
standards for motor vehicle safety. Only a peremptory
mandate to NHTSA to implement Standard 208 with 1984
models, if physically possible, will carry out the will of
Congress and conform to the clearly established efficacy of
installing the passive restraint systems. Any arguments
by the automobile industry that it will not be able to comply
should be rejected out of hand, since the industry has been
on notice of its responsibility for nearly a decade (Pet.
App. 6a).

15

Conclusion

The judgment of the Court of Appeals for the District
of Columbia Circuit should be affirmed.

Dated: New York, New York
February 7, 1982

Respectfully submitted,

Ropert ABRAMS
Attorney General of the
State of New York
Attorney for Respondent .
Superintendent of Insurance

Perer H. Scuirr
Acting Attorney-in-Chief
Appeals and Opinions
Rosert S. HAMMER
Assistant Attorney General

MARTIN a ‘
Deputy Superintendent an
General Counsel

Mitton L, FreepMan
Assistant Deputy Superintendent
and Counsel

New York State Insurance Department
Of Counsel

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385009_0696%3A18. Public record. Not legal advice.